The Tax Court issued a nine to eight split decision of six opinions (three in favor and three dissenting) upholding the Service’s 1994 blocked income regulations. Yesterday, February 9, 2023,…
…the Commission. The Commission must regroup to undertake its State aid analysis investigations using the Member States’ transposition of the arm’s length standard. Professor William Byrnes, author of several tax…
On August 25, 2022, the Sixth Circuit Court of Appeals answered a fundamental question about advance pricing agreements (APAs): Is an APA a contract between the IRS and a taxpayer?[1]…
…into the facts and analysis of Medtronic I and II, see William Byrnes, Practical Guide to U.S. Transfer Pricing (4th Ed.). This brings us up to speed for Medtronic III….
The U.S. has a highly successful international financial service industry that is important to the U.S. economy, exemplified by, firstly, the international financial centers such as Miami and New York…
We commend the OECD’s 15-year effort since its 2005 publication of E-commerce: Transfer Pricing and Business Profits Taxation to address the challenges arising from the digitalization of multinational enterprises’ business…
…the Indian High Courts. See Jayshree Tea and Industries Ltd. v. Union of India (2002) 253 ITR 608 (Calcutta) available at https://indiankanoon.org/doc/1617131/ and George Williamson (Assam) Ltd. v. Union of…
…Subcommittee on Select Revenue Measures March 31, 2009, Accessed from https://www.ctj.org/pdf/mcintyresw&mtestimony20090331.pdf on 4th March 2020 [4] Ibid. [5] William Byrnes and Robert J. Munro, Background and Current Status of FATCA,…
…address their concerns in the context of the system already built to deal with them, withholding tax. [1] Feb. 8, 1968, the New York Times. William Byrnes is a professor…
Our 14-page comments and recommendations of 14 tax professionals and academics from 11 countries raise additional issues and concerns, and propose additional recommendations to undertake a detailed cost benefit analysis…
…Texas A&M University School of Law Prof. William H Byrnes, IV (U.S.A.) & Dr. Bruno Da Silva (Portugal), Course Professor Pramod Kumars (France) & Susanna Hartanto (Indonesia) Tetiana Zakrevska (Singapore)…
In my International Taxation class tomorrow (October 10th) we are going to discuss the OECD’s “Unified Approach” released a day earlier on October 9, 2019. Given the keen interest generated…
William Byrnes, Texas A&M University School of Law* (33-page draft research available on SSRN) Howdy! Earlier today the General Court of the European Court of Justice (EGC) sided with Starbucks’…
…See also my comments about Altera: An ‘arm’s length result is not simply any result that maximizes one’s tax obligations’. Prof. William Byrnes (Texas A&M) is the author of a…
