William Byrnes

On Thursday, August 18, 2022, Chief Judge Kathleen Kerrigan of the U.S. Tax Court published her 75-page decision on the Medtronic and I.R.S. controversy (“Medtronic III”).[1] This decision resulted…

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…

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…

Since 2013 the OECD has worked on forging a grand coalition (now 136 countries) it calls the “Inclusive Framework” around adopting the outcomes of the OECD’s Base Erosion and Profit Shifting (BEPS)…

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…

We applaud 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…

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 by…

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’…

I have received several requests this July 4th holiday in the U.S. about my initial thoughts on the EU Commission's 56-page published (public version from earlier this week) State Aid preliminary…