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…
What do these two things have in common? Dr. Andrew P. Morriss, Dean & Anthony G. Buzbee Dean’s Endowed Chair, Texas A&M School of Law explains In 1998, seven US…
After a decade, the Treasury Department issued a new U.S. Model Income Tax Convention (the “2016 Model”), which is the baseline text the Treasury Department uses when it negotiates tax…
MNC profit shifting has received major attention over the past few years. Total earnings stockpiled overseas are now reported to be in excess of $2 trillion. One of the authors…
…information as, but need not be identical to, the paper Form W-8. Prof. William Byrnes is the author of Guide to FATCA Compliance – 2016 Edition IRS FATCA Notice 16-08…
…U.S. Law (Congressional Research Service, Feb 18, 2015) Prof. William Byrnes of Texas A&M University is the author of the treatise Practical Guide to U.S. Transfer Pricing and Foreign Tax…
…January 2016 182,649 For further FATCA GIIN, CRS, and LEI analysis, see Perryman and Byrnes’ work in the Guide to FATCA Compliance. Origin Registrations (January 1, 2015) Registrations (January 1,…
…€20m to €30m on top of the $3 billion in global taxes we have already paid over the seven years in question (2008-2014).” Professor William Byrnes (Texas A&M) is the…
…173,346 October 175,543 November 177,147 For further GIIN analysis by country and by entity type, see Byrnes’ Guide to FATCA Compliance. Update – FATCA November IDES and ICMM Frequently Asked…
…William Vickrey, The Corporate Income Tax and How to Get Rid of It, Retrosprective on Public Finance, 1991, Duke University Press, pp. 118-132 and Richard M. Bird, Why Tax Corporations?,…
…as William Byrnes observed in his recent post, the differences accounted in dollars would not necessarily be significant. Moreover, in order to obtain such a favourable position, the tax authorities…
Both Starbucks and Fiat represent, if one listened closely to the live press release broadcast, an first salvo by the EU Commission to establish that it has the authority, under…
