Wednesday, September 21, 2016
Saturday, August 20, 2016
Friday, August 19, 2016
Wednesday, August 10, 2016
Monday, August 8, 2016
Sunday, August 7, 2016
Thursday, August 4, 2016
Wednesday, August 3, 2016
Tuesday, August 2, 2016
Monday, August 1, 2016
Saturday, July 30, 2016
Friday, July 29, 2016
Thursday, July 28, 2016
Wednesday, July 27, 2016
Tuesday, July 26, 2016
Monday, July 25, 2016
Sunday, July 24, 2016
Saturday, July 23, 2016
Friday, July 22, 2016
Monday, July 18, 2016
Saturday, July 16, 2016
Friday, July 15, 2016
Thursday, July 14, 2016
Wednesday, July 13, 2016
Tuesday, July 12, 2016
Monday, July 11, 2016
Saturday, July 9, 2016
Thursday, July 7, 2016
Wednesday, July 6, 2016
Tuesday, July 5, 2016
Friday, July 1, 2016
Thursday, June 30, 2016
Wednesday, June 29, 2016
Tuesday, June 28, 2016
Thursday, June 23, 2016
Wednesday, June 22, 2016
Tuesday, June 21, 2016
Monday, June 20, 2016
Wednesday, June 15, 2016
Tuesday, June 14, 2016
Monday, June 13, 2016
Friday, June 10, 2016
Thursday, June 9, 2016
Friday, June 3, 2016
Wednesday, June 1, 2016
Tuesday, May 31, 2016
Friday, May 27, 2016
Thursday, May 26, 2016
Wednesday, May 25, 2016
Thursday, May 19, 2016
Wednesday, May 18, 2016
Tuesday, May 17, 2016
Friday, May 13, 2016
Tuesday, May 10, 2016
Monday, May 9, 2016
Friday, May 6, 2016
Thursday, May 5, 2016
Sunday, May 1, 2016
Friday, April 29, 2016
SSRN tax professor top 25 global rankings released
Texas A&M has placed two tax professors in the SSRN tax professor top 25 ranked (for the previous year category): Dr. Jack Manhire and William Byrnes
Thursday, April 28, 2016
Wednesday, April 27, 2016
Tuesday, April 26, 2016
Monday, April 25, 2016
Sunday, April 24, 2016
Thursday, April 21, 2016
Wednesday, April 20, 2016
Trade Facilitation Act and its impact on IP policy in India
Trade Facilitation Act and its impact on IP policy in India: On February 24, 2016, U.S. President Barack Obama signed the Trade Facilitation and Trade Enforcement Act of 2015, which introduces important measures relating to intellectual property rights (IPR) i
Tuesday, April 19, 2016
Monday, April 18, 2016
Sunday, April 17, 2016
Friday, April 15, 2016
Thursday, April 14, 2016
Wednesday, April 13, 2016
Tuesday, April 12, 2016
Monday, April 11, 2016
Friday, April 8, 2016
Thursday, April 7, 2016
Tuesday, April 5, 2016
Commentary on the The Panama Papers Disclosing 14,000 Clients' 214,000 Companies Files: tax evasion, political corruption, and FIFA connections
International Financial Law Prof Blog
"When the complete list of 14,000 persons and each's connections to offshore assets is published in early May by ICIJ, expect a free for all by the criminal investigative departments of the revenue authorities from the 200 countries uncovered in the files," said Prof. William Byrnes of Texas A&M University's School of Law. "This is the fifth major, game-changing, leak of offshore records, including Portcullis Trust (Singapore), HSBC, UBS, and LuxLeaks."
"When all the leaked data is combined with all the thousands of taxpayer and offshore advisor files gleaned from offshore voluntary compliance and non-prosecution programs, then crunched with AI (artificial intelligence, or neural network) programs that "connects the dots", many additional politicians and business leaders are going to be exposed to criminal and civil tax and corruption investigations." continued William Byrnes. "I think many have been trying to run out the clock by suppressing this information. For some countries that strategy may work, but others countries will experience televised perp walks and political backlash."
Professor William Byrnes added, "I expect to see investigations and prosecutions of attorneys and staff of Mossack Fonseca, and eventual extradition. Perhaps the firm will enter into nonprosecution agreements with governments, pay a fine, like the Swiss banks and several Big 4 accomplished, and turn over its remaining client files. It may be an end to the firm, but when its partners and staff are faced with a choice of either US and other countries long term prison sentences or providing evidence against clients, the clients are going to be 'thrown under the bus'."
** download here for free Prof. William Byrnes 118 page in-depth analysis of tax information exchange, FATCA and CRS ** “In the field of international tax, Prof. William Byrnes is among LexisNexis’s best-selling authors and a leading authority in the fields of anti-money laundering and FATCA compliance.” Ray Camiscioli, Esq., Director, Product Strategy & Development for Tax, Accounting and Estates/Elder Law, LexisNexis, Inc.
Professor William Byrnes pivoted in the discussion, “The US has a highly successful international financial service industry that is important to the US economy, exemplified by, firstly, the international financial centres such as Miami and New York) of over a half trillion dollars of foreign deposits of high net wealth individuals whom many experts allege are not tax and exchange control compliant in their home countries; secondly, over 900,000 Delaware companies is the second to Hong Kong, and ahead of British Virgin Islands (BVI is actually third in the world);[1] and thirdly, the US territories’ offshore regimes, reducing the effective US corporate and income tax rates below 3.5 percent.[2]”
"In 2011, 133,297 businesses incorporated in Delaware. Delaware has more corporate entities than people — 945,326 to 897,934," he continued. "These absentee corporate residents account for a quarter of Delaware’s total budget, roughly $860 million in taxes and fees in 2011.[3] Moreover, the economic spill-over impact for Delaware includes substantial employment and professional fees to Delaware business participating in the incorporation and advisory industry. Delaware is just behind China’s Hong Kong in number of annual incorporations and overall incorporations, and well ahead of the UK’s Virgin Islands (British) both in terms of offshore business and the dollars earned from that offshore business. Thus, I wonder how many of these Delaware companies, and Delaware corporate service providers, will be exposed once the data is disclosed by ICIJ in May?"
[1] “Storm Survivors”, Special Report: Offshore Finance, The Economist, 16 Feb 2013.
[2] See William H Byrnes and Dr. Robert J Munro, Tax Havens of the World, US Virgin Islands chapter, LexisNexis. See also Prof. William Byrnes' 118 page in-depth analysis of tax information exchange, FATCA and CRS.
[3] See Wayne, Leslie, How Delaware Thrives as a Corporate Tax Haven, New York Times (June 30, 2012).
Thursday, March 31, 2016
Wednesday, March 30, 2016
Tuesday, March 29, 2016
Friday, March 25, 2016
Monday, March 21, 2016
Sunday, March 20, 2016
Tuesday, March 15, 2016
free download of Lexis FATCA Compliance Analysis 118 pages
link here http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2742383
The LexisNexis® Guide to FATCA Compliance provides a framework for meaningful interactions among enterprise stakeholders, and between the FATCA Compliance Officer and the FATCA advisors/vendors. Analysis of the complicated regulations, recognition of overlapping complex regime and intergovernmental agreement requirements (e.g. FATCA, Qualified Intermediary, source withholding, national and international information exchange, European Union tax information exchange, information confidentiality laws, money laundering prevention, risk management, and the application of an IGA) is balanced with substantive analysis and descriptive examples. The contributors hail from several countries and an offshore financial center and include attorneys, accountants, information technology engineers, and risk managers from large, medium and small firms and from large financial institutions. Thus, the challenges of the FATCA Compliance Officer are approached from several perspectives and contextual backgrounds.
Several new contributing authors joined the FATCA Expert Contributor team this fourth edition. This fourth edition has been expanded by 19 new chapters and from a total of 54 to 73 chapters, with over 500 new pages of regulatory and compliance analysis based upon industry feedback of internal challenges with systems implementation. The previous 54 chapters have been substantially updated and expanded, including many more practical examples to assist a compliance officer contextualize the regulations, IGA provisions, and national rules enacted pursuant to an IGA. The new chapters include by example an in-depth analysis of designing a FATCA internal policy that is compliant with the initial two year soft enforcement initiative, designing an equivalent form to the W-8, reporting accounts, reporting payments, operational specificity of the mechanisms of information capture, management and exchange by firms and between countries, insights as to the application of FATCA and the IGAs within new BRIC and European country chapters, and a project management schedule for the compliance officer.
link here http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2742383
The LexisNexis® Guide to FATCA Compliance provides a framework for meaningful interactions among enterprise stakeholders, and between the FATCA Compliance Officer and the FATCA advisors/vendors. Analysis of the complicated regulations, recognition of overlapping complex regime and intergovernmental agreement requirements (e.g. FATCA, Qualified Intermediary, source withholding, national and international information exchange, European Union tax information exchange, information confidentiality laws, money laundering prevention, risk management, and the application of an IGA) is balanced with substantive analysis and descriptive examples. The contributors hail from several countries and an offshore financial center and include attorneys, accountants, information technology engineers, and risk managers from large, medium and small firms and from large financial institutions. Thus, the challenges of the FATCA Compliance Officer are approached from several perspectives and contextual backgrounds.
Several new contributing authors joined the FATCA Expert Contributor team this fourth edition. This fourth edition has been expanded by 19 new chapters and from a total of 54 to 73 chapters, with over 500 new pages of regulatory and compliance analysis based upon industry feedback of internal challenges with systems implementation. The previous 54 chapters have been substantially updated and expanded, including many more practical examples to assist a compliance officer contextualize the regulations, IGA provisions, and national rules enacted pursuant to an IGA. The new chapters include by example an in-depth analysis of designing a FATCA internal policy that is compliant with the initial two year soft enforcement initiative, designing an equivalent form to the W-8, reporting accounts, reporting payments, operational specificity of the mechanisms of information capture, management and exchange by firms and between countries, insights as to the application of FATCA and the IGAs within new BRIC and European country chapters, and a project management schedule for the compliance officer.
link here http://papers.ssrn.com/sol3/papers.cfm?abstract_id=2742383
Friday, March 11, 2016
Thursday, March 3, 2016
Monday, February 29, 2016
Thursday, February 25, 2016
Wednesday, February 24, 2016
Tuesday, February 23, 2016
Friday, February 19, 2016
Thursday, February 18, 2016
Friday, February 12, 2016
Wednesday, February 10, 2016
Tuesday, February 9, 2016
Thursday, February 4, 2016
Tuesday, February 2, 2016
Monday, February 1, 2016
Thursday, January 28, 2016
Wednesday, January 27, 2016
Tax Considerations of Foreign Individual Investors in U.S. Real Estate Investment
International Financial Law Prof Blog
Tax Considerations of Foreign Individual Investors in U.S. Real Estate Investment - This Mertens Highlight will first present the landscape of foreign investment in the U.S. real estate market over the past seven years, contrasting Canadian and Chinese real estate investors. Secondly, this Highlight will discuss the general tax considerations for real estate investment, and the Code provisions attaching thereto. In the remaining parts, the foreign real estate investor specific concerns regarding FIRPTA and the U.S. estate tax, with common planning opportunities, will be reviewed.
Tax Considerations of Foreign Individual Investors in U.S. Real Estate Investment - This Mertens Highlight will first present the landscape of foreign investment in the U.S. real estate market over the past seven years, contrasting Canadian and Chinese real estate investors. Secondly, this Highlight will discuss the general tax considerations for real estate investment, and the Code provisions attaching thereto. In the remaining parts, the foreign real estate investor specific concerns regarding FIRPTA and the U.S. estate tax, with common planning opportunities, will be reviewed.
Saturday, January 23, 2016
Wednesday, January 20, 2016
Friday, January 15, 2016
Wednesday, January 13, 2016
Tuesday, January 12, 2016
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