In a double take two-to-one decision because of a withdrawn decision due to the death of a judge, a Ninth Circuit panel in Altera reversed a unanimous en banc decision…
…then derogates from the exemption with a series of BEPS measures.[1] by William Byrnes, Texas A&M University Law On Thursday, November 2, 2017, the Republicans of the House of Representatives’…
…Guide to U.S. Transfer Pricing Professor William Byrnes seminal treatise, provides the expertise multinationals require to cope with transfer pricing rules, regulations, compliance reports, and controversy, taking into account the…
FATCA: GIINs and LEIs Musings of Professor William Byrnes with the tremendous brain power of Haydon Perryman Firstly, a loud shout out to Haydon Perryman who crunches the IRS GIIN…
…see Byrnes, William, Guide to FATCA & CRS Compliance (Matthew Bender 5th ed., 2017) at pp. 30, 33-34, 50, 59, 109-112, and 119-122. https://papers.ssrn.com/sol3/papers.cfm?abstract_id=2926119 Byrnes, William, How May the United…
…a motion seeking the release of 16 documents that are in the public record but remain under seal. About me: Prof. William Byrnes (Texas A&M) is the primary author of…
…based on a Better Way align with the likely industry needs of the Brave New World of BEPS and CbCR. [download my OECD v US transfer pricing regulations article] William…
…November, allowing me December to pull together a publishable quality law review article. Meanwhile, please keep your feedback coming: williambyrnes@tamu.edu. By brief background, on 27 June 2016 the EU Commission…
This month I am going to present the first part (the justification) of a Congressional proposal that I am working upon for an academic article (I will appreciate any feedback)….
…rudimentarily commit to a sustainable coffee sourcing and often can only track their coffee source to the importer (see below figure).[23] Source: http://www.verite.org/Commodities/Coffee Professor William Byrnes is the author of…
William Byrnes with Haydon Perryman This month we turn our attention to the recently revised 2016 W-8BEN-E form which has 30 parts over eight pages that can be catalogued into…
In highly dramatic fashion the French tax authorities and IT specialists raided Google’s headquarters and McDonalds. I don’t own Google stock. I’m not in favor of Google’s near monopoly on…
This month I will discuss the important topic for the anti-money laundering compliance officer, wherein the AML systems overlap with the requirement for tax compliance, and that tax compliance requirement…
…Procedures in Prof. William Byrnes’ Practical Guide to U.S. Transfer Pricing as well as analysis of the LB&I reorganization, year-by-year data, and new examination process. Survey of Submitted and Completed…
