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International Tax & Transfer Pricing Certificates or LL.M. / Master Legal Studies at Texas A&M

Posted by William Byrnes on August 21, 2025


International Tax & Transfer Pricing (non-degree) Certificates or LL.M. (for law graduates) / Master Legal Studies (for accountants, economists, and financial professionals) are designed for an in-depth study of tax risk management.

Sample of Courses (see graduate programs catalog)

  • Transfer Pricing l – Methods, Econometrics, and Tangibles – January start
  • Transfer Pricing II – Services and Intangibles – March start
  • International Tax Risk Management I – Data, Analytics, and Technology
  • International Taxation and Treaties I – residency issues – August start
  • International Taxation and Treaties II – source issues – October start
  • Inhouse Tax Counsel: Tax Systems and Risk Management – summer
  • Domestic (Inbound) Tax Risk Management – August start
  • U.S. International Tax Risk Management – Data and Analytics – Spring
  • U.S. International Tax Risk Management – Law and Regulation – Summer
  • FATCA, CRS, and AEoI Risk Management – summer
  • European Union Tax Risk Management – March start

Example of Weekly Case Study for Domestic (Inbound) Tax Risk Management Week 1: Aug 25 – Aug 31

A seven-week course case study, where you will serve as the new in-house international tax team, focused on its foreign operations, of Natmed Serland SA, one of the leading global FMCG Companies. The week before you must report to the office, your inhouse team has been provided Natmed’s operational briefing, department (functional) interviews briefing, and all relevant financials. Your team must come together before the first week and discuss Natmed because for your first week in the office, your team will hit the ground running. The Board of Directors has instructed the in-house tax department to brief the Operational Board weekly for one hour, over six weeks, on a specific tax risk topic area related to NatMed’s overall tax risk management and financial health. In the seventh week, at the annual Full Board meeting, your team has been granted an hour, hard-stop time slot on the agenda to provide its final tax risk management prognosis of Natmed Serland. 

Your faculty case study facilitators consists of Pramod Kumar (International Tax Director, Michelin North America); Hafiz Choudhury (M Group Principal); Dr. Maji Rhee (Dean, Center for International Education; Professor, Faculty of International Research and Education, School of International Liberal Studies, Waseda University) and Professor William Byrnes.

For week 1, Pramod Kumar, our in-house tax director expert, will lead the week 1 and week 2 learning on tax risk management concerning our fictional Natmed Serland SA, one of the world’s largest natural-healthcare groups with revenues exceeding €1.28 billion and a legacy that stretches back more than a century, earns 95 percent of its turnover outside its small European home market. Late on a Friday in August 2025, U.S. trade officials announce an immediate 18 percent customs duty on imported herbal creams and toothpastes—core items within Natmed’s flagship “Natmed” and “Natca” ranges. Overnight, margins on American sales collapse.

That same evening the chief executive summons the in-house tax team. A lifeline has appeared: the founding family of GreenLeaf Botanicals LLC, a New-Jersey contract manufacturer that already toll-produces half of Natmed’s leading balm for private-label chains, is willing to sell. For USD 640 million in cash, Natmed can acquire 100 percent of GreenLeaf, re-domesticating production and escaping the new tariff. Exclusivity on the offer, however, expires in ten calendar days. The tax department must determine whether the deal truly neutralizes the duty hit, estimate the combined U.S. effective-tax-rate under domestic tax rules, and craft the deal tax covenants before the board will vote. 

The executive leadership has entrusted the mandate to its in-house Tax team with full autonomy—ask every question, run any model, and decide with the best information you can gather before Day 10. The information available is posted in your Canvas classroom case study folder

Week 1 Analysis and deliverables

  • As the tax department, draft a one-page “Go / No-Go” executive memorandum that frames the deal’s upside, flags the unresolved risks, and proposes a tax covenant that the board could insist on before signing. This must be submitted to the board by the evening of August 31, 8 pm Central (Dallas).
  • Prepare and deliver the tax department’s presentation to the executive board members meeting via Zoom on Monday evening.
  • Meanwhile, William Byrnes will lead this week’s learning for the One Big Beautiful Bill Act (OBBBA) updates to the U.S. Subpart F regime.  
  • Research Practicum: William Byrnes will undertake a show-and-learn using the IBFD.

Certificate and Degree candidates are exposed to (i) international tax laws, regulations, and policies in the international tax risk management field, (ii) technology and tax data management, and (iii) weekly practice case studies using Zoom and team groups. Individuals who complete the program will be able to synthesize scenarios, practice, and legal regulation in the international tax risk management field, providing analysis or judgments for consideration to organizational leadership with a nuanced perspective.

Courses are offered by asynchronous distance learning to provide a flexible schedule for working professionals. Interactive coursework includes case study assignments and regular interaction with classmates & the faculty through twice-weekly Zoom meetings (recorded), pre-recorded videos, audio casts, discussion boards, and group breakout sessions.  For more information, contact Admissions: https://www.law.tamu.edu/admissions-aid/how-to-apply/index.html

Texas A&M system’s operating budget of $7.3 billion (FY2025), R&D grants & expenditure exceed $1.5 billion, and capital budget of $5.1 billion includes the new law school anchored billion-dollar campus in Fort Worth, is one of only 60 accredited universities of the American Association of Universities (R1: Doctoral Universities – Highest Research Activity) and one of only 17 universities that hold the triple U.S. federal grant of Land, Sea, and Space!

Texas A&M law school is ranked #1 in the U.S. for employment outcomes (“gold standard” law jobs) – the fifth consecutive year the law school has ranked in the top 10 nationally. The law school is ranked in the first tier (#22 overall). The Wall Street Journal, focusing on career outcomes, ranks Texas A&M #28 in the nation (#11 of public universities) and #1 in Texas. PreLaw Magazine ranks Texas A&M #5 for best value (tuition: career outcome). Texas A&M has the largest (#1) foundation endowment for U.S. public universities, #7 overall (US News 2025). Texas A&M has the most CEOs (#1) of Fortune 500 and Fortune 100 mutlinationals. Texas A&M ranks #1 in Texas for value (2025).

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Release of Taxation of IP & Technology Update for 2020

Posted by William Byrnes on November 11, 2019


Taxation of Intellectual Property and Technology 2020 edition is a 1,000 page analytical treatise to the federal tax consequences of the development, purchase, sale and licensing of intellectual properties and intangibles.  Primary author William Byrnes leads a team of America’s leading tax senior counsel to analyze tax risk challenges for business and investment decisions concerning intellectual property, technology, intangibles, and the digital economy. This 2020 update published in November (next update published in June 2020) contains:

  • Expands this treatise beyond 1,000 pages of analysis and planning research.
  • Provides in-depth analysis of the 2019 final and proposed regulations that impact intellectual property and intangibles, including GILTI and FDII.
  • Analyzes the new Cloud Computing Regulations.
  • Expanded analysis of the 2018 Supreme Court Wayfarer decision and its impact on interstate digital business models and trademark holding companies.
  • Analysis of several 2019 decisions cases including AmazonAlteraSlaughterhouse.

Major revisions this update, by chapter, include:

  • GILTI regulations. The final and newly proposed GILTI regs are analyzed in depth in § 2.04[8].
  • FDII regulations. The proposed regulations are explained in depth in § 2.04[9].
  • Cloud Computing Regulations. The proposed regulations are explained in depth in § 2.05[3] and § 10.02[2][c][iii][G].
  • International Transactions. Chapter 12 has been substantially revised and additional analysis of the Service Regulations as well as the Cost Sharing Regulations in light of Amazon and Altera.
  • Economic presence tax nexus and digital services tax. See analysis within Chapters § 11.09, § 14.07[6] and § 15.05[1].
  • Wayfarer’s Impact. On taxation of holding companies, see § 4.06. On tax nexus and sales tax, see Chapter § 11.04.
  • Taxation of Emerging Technologies for Cloud Computing, Blockchain, and Artificial Intelligence. See Chapter § 10.02[2][c].
  • Slaughter v Comm’r. IRS argued that the author’s promotion for the publisher which builds her brand is her trade or business and thus her royalties are net earnings from self-employment. Analyzed and critiqued in Chapter § 1.06[4].

New domestic and internationally focused chapters are in development by treatise author Prof. William Byrnes (Texas A&M Law) for 2020, including on the valuation of intangibles, tax considerations for entrepreneurs, and country analysis chapters. His team of internationally recognized expert practitioners provide strategic and tax risk analysis: Carlos Perez Gautrin, Yair Holtzman, Iselle Coronado-Torres, Jeffrey Trey, Arinjay Kumar Jain, Leonardo Macedo, Venetia Argyropoulou, Pamela Ann Fuller, William Seeger, Lucia Valenzuela, and Charles Lincoln. Please contact William Byrnes with chapter proposals. Taxation of Intellectual Property Publication Update (2019)

Nine seats remain for the Spring (4 teams of 3 students each) to join the current 4 teams January 13 – April 20 semester for TRANSFER PRICING course taught by Dr. Lorraine Eden, Prof. William Byrnes, TP Aggiesand several industry experts. The courses count toward the INTERNATIONAL TAX online Master curriculum of Texas A&M for tax attorneys, accountants, and economists. Taught live twice weekly using Zoom involving teams working to design positions and solutions for real-world post-BEPS client studies each week, supported by originally authored materials, videos and audio casts, PPTs, and a robust online law & business database library.  For more information, contact Texas A&M Admissions https://info.law.tamu.edu/international-tax

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