Skip to content

Kluwer International Tax Blog

Kluwer International Tax Blog
  • Facebook
  • X
  • LinkedIn
  • YouTube

Search Results for: william byrnes

BEPS, MAPs and APAs, OECD, Permanent Establishments, Tax Planning, Transfer Pricing

Texas Hold’em Poker: France Bet Google & McDonalds. Will U.S. Treasury Double Down?

William Byrnes (Texas A&M University Law)/May 30, 2016 /Leave a comment

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…

FATCA, OECD

The Brave New World of AML and Tax Compliance Overlap for Tax Status Certification for FATCA, CRS and the EU. Why are so many compliance officers getting it wrong?

William Byrnes (Texas A&M University Law)/May 9, 2016 /3 Comments

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…

BEPS, Transfer Pricing

U.S. APA Transfer Pricing and LB&I ReStructure / Audit Process Update

William Byrnes (Texas A&M University Law)/April 11, 2016 /Leave a comment

…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…

BEPS, Tax Planning

What Do Heavy-Duty Diesel Engines And The Google Tax Have in Common?

William Byrnes (Texas A&M University Law)/March 4, 2016 /1 Comment

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…

Tax Treaties

Analysis of the New US Model Tax Treaty

William Byrnes (Texas A&M University Law)/February 25, 2016 /Leave a comment

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…

BEPS, Tax Planning

Profit shifting: Effectively Connected Income and Financial Statement Risks

William Byrnes (Texas A&M University Law)/February 16, 2016 /1 Comment

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…

FATCA, Tax Planning

Analysis of IRS Notice 2016-8: FATCA Extensions and Reliance Upon Electronic W8 / W9s

William Byrnes (Texas A&M University Law)/February 1, 2016 /Leave a comment

…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…

BEPS, EU/EEA, MAPs and APAs, State Aid, Tax Planning, Tax Treaties, Withholding Taxes

Will the US Impose Double US Tax Rates on EU Companies from Countries that Retroactively Impose State Aid Claw Backs?

William Byrnes (Texas A&M University Law)/January 26, 2016 /2 Comments

…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…

FATCA, OECD, Tax Avoidance, Tax Fraud

2015’s FATCA GIIN Analysis

William Byrnes (Texas A&M University Law)/January 20, 2016 /Leave a comment

…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,…

BEPS, State Aid, Transfer Pricing

The Netherlands Appeals the Starbucks Decision

William Byrnes (Texas A&M University Law)/December 9, 2015 /Leave a comment

…€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…

FATCA

FATCA November GIIN and IDES Updates

William Byrnes (Texas A&M University Law)/November 25, 2015 /Leave a comment

…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…

BEPS, CCCTB, EU/EEA, OECD, Tax Avoidance, Tax Planning, Tax Policy

Darwin & Corporate Taxation – Has the Evolution of the Economy Killed the Basis for Corporate Taxation?

Jakob Bundgaard (CORIT advisory)/November 23, 2015 /2 Comments

…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?,…

BEPS, EU/EEA, Transfer Pricing

The Interplay between the State Aid Rules and other BEPS-Preventing Tools (SA.38375)

Emanuela Matei (Mircea and Partners Law Firm)/October 28, 2015 /1 Comment

…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…

BEPS, State Aid, Tax Planning, Transfer Pricing

EU Commission State Aid Starbucks Decision – My U.S. Perspective

William Byrnes (Texas A&M University Law)/October 23, 2015

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…

Posts navigation

12345
Wolters Kluwer

Browse Categories

RSS feeds

Summary Feed Article Feed

Recent publication

10058516-0002_OR2_290Schwarz on Tax Treaties, Sixth EditionJonathan Schwarz€ 211

Contributors

  • Svetislav V. Kostić (Managing Editor)
    University of Belgrade, Faculty of Law
  • Vikram Chand (Editor)
    Tax Policy Center of the University of Lausanne, Switzerland
  • Alice Pirlot (Editor)
    Geneva Graduate Institute
  • Dennis Weber (Editor)
    Amsterdam Centre for Tax Law (ACTL) of the University of Amsterdam; Loyens & Loeff
  • Błażej Kuźniacki
    PwC Netherlands, Lazarski University and Singapore Management University
  • Johann Müller
    International tax professional
  • Jakob Bundgaard
    CORIT advisory
  • William Byrnes
    Texas A&M University Law
  • Werner Haslehner
    Luxembourg University
  • Tianlong Hu
    Law School and International Monetary Institute, Renmin University of China
  • Christian Kaeser
    Siemens AG
  • Theo Keijzer
    Dorean Global Tax Policy BV
  • Guglielmo Maisto
    Maisto e Associati
  • Georgios Matsos
    Matsos & Associates
  • Luis Schoueri
    University of Sao Paulo; Lacaz Martins, Pereira Neto, Gurevich & Schoueri Advogados
  • Jonathan Schwarz
    Temple Tax Chambers; King’s College London
  • Guillermo O. Teijeiro
    Bomchil
  • Ana Claudia Akie Utumi
    Utumi Advogados
  • Piergiorgio Valente
    Crowe Valente/Valente Associati GEB Partners; Link Campus University, Rome

Related Sites

  • Kluwer International Tax
  • Author Portal
Kluwer Logo

About Us

  • About Kluwer International Tax Blog
  • Kluwer International Tax Law
  • Kluwer Law International
  • E-store
  • Authors

Legal Policy

  • User Agreement and Disclaimer
  • Editorial Policy & Guidelines
  • Privacy Policy and Use of Cookies

Contact

  • General information
Back to top