Based on weekly case studies created by the faculty, supported by reading/text materials, pre-recorded videos with PPTs, and audio podcast files made by the faculty – twice-weekly Zoom live sessions (recorded as well) of 90 – 120 minutes wherein students in teams work through the case studies generally from an assigned stakeholder perspective. Access to the extensive Texas A&M library for case study research includes by example: Lexis, Westlaw, IBFD, Kluwer-Cheetah, Thomson OneSource, BvD (Moodys), S&P CapIQ, FITCH, among several others. Apply for Texas A&M’s courses here.
- Transfer Pricing Risk Management I Tangibles, Methods, Economics, and Data
- Transfer Pricing Risk Management II: Intangibles, Services, Pillar 1/Digital, Formulary
- U.S. Tax Risk Management (Data, Analytics & Technology)
- E.U. Tax Risk Management
U.S. Tax Risk Management (Data, Analytics & Technology) syllabus
- Week 1 January 19, 2021 Outbound / FDII Melissa Muhammad (IRS LB&I)
- Week 2 January 25, 2021 Inbound / BEAT Melissa Muhammad
- Week 3 February 1, 2021 International Reporting/Technology Documentation (Forms 5471, 8865, 8858, 8832): Neelu Mehrotra: EY
- Week 4 February 8, 2021 [Understanding Subpart F & Form 5471 and 1120 Documentation}: Neelu Mehrotra: EY
- Week 5 February 15, 2021 Understanding Subpart GILTI and PTEP and Form 8992: Neelu Mehrotra: EY
- Week 6 February 22, 2021 FTCs; wrap-up: Melissa Muhammad
- Capstone Week March 1
E.U. Tax Risk Management syllabus
- Week 1 March 8, 2021 E.U. General Framework of Compliance Tax Risk Management Dr. Eva Andrés (Barcelona)
- Week 2 March 15, 2021 Parent Subsidiary Directive, Interest, Royalties. Dr. Santiago Ibañez Marcilla
- Week 3 March 22, 2021 The European Union proposal on a carbon border tax and its compatibility with the World Trade Organization rules Dr. Xavier Fernández Pons
- Week 4 March 29, 2021 Free Movement of Capital (investment funds) and others Fundamental Freedoms. Dr. Eva Andrés & Dr. Andreu Olesti
- Week 5 April 5, 2021 Cross-Border Losses – Dr. Bruno Da Silva
- Week 6 April 12, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva
- Capstone Week April 19-25: Build a client case study, wrap up
Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes course materials) syllabus
- Week 1 January 19 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva & William Byrnes
- Week 2 Jan 25 CUP & Comparables Dr. Lorraine Eden
- Week 3 Feb 1 Cost Plus & Resale Minus Dr. George Salis
- Week 4 Feb 8: Comparable Profits Method & TNMMDr. George Salis
- Week 5 Feb 15 Profit Split Dr. George Salis
- Week 6 Feb 22 Best Method Dr. Lorraine Eden
- Capstone Week March 1
Transfer Pricing Risk Management: Intangibles and Services (William Byrnes course materials) syllabus
- Week 1 March 8 Intangibles Royalty Rates CUT, CPM Dr. Debora Correa Talutto
- Week 2 March 15 CSA Intangibles Buy In/Out Dr. George Salis & William Byrnes
- Week 3 March 22 Digital Business Unitary Apportionment Dr. Bruno Da Silva
- Week 4 March 29 Digital Value Chain, Internet of Things Dr. Lorraine Eden
- Week 5 April 5 U.S. v OECD v UN Manual case study Extractive Industries, Financing Hafiz Choudhury
- Week 6 April 12 Restructuring the Business, Services case study Hafiz Choudhury
- Week 7 April 19 Capstone Hand-On Week with Financial databases “Tax Technology and the future of Transfer Pricing” Dr. Debora Correa Talutto Thomson OneSource, BvD (Moodys), and CrossBorder AI Solutions Dr. Debora Correa Talutto & William Byrnes
Texas A&M, an annual budget of $6.3 billion (FY2020), is the largest U.S. public university, one of only 60 accredited U.S. universities of the American Association of Universities (R1: Doctoral Universities – Highest Research Activity) and one of only 17 U.S. universities that hold the triple U.S. federal grant of Land, Sea, and Space!
- Ranked in top 20 public universities by Wall Street Journal / Times Higher Education (2020)
- #1 endowment for U.S. public universities, #7 overall
- #1 of U.S. public universities for a superior education at an affordable cost
- #1 for most CEOs employed by Fortune 500
- Rank 11th “Best Public Colleges” Money’s Best Colleges Report, 2019
- Texas A&M ranks #1 in Texas, #1 in the SEC, and #12 in the U.S. in Washington Monthly’s 2020 overall college rankings based on the quality of education, accessibility, graduation rates, student involvement, and research: see tx.ag/WashMonth20
William Byrnes' Tax, Wealth, and Risk Intelligence 