Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programWe appreciate the opportunity to provide input on this historic effort…
Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate program.AbstractThe European Union has transposed Pillar Two into EU law,…
Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programAbstractWe appreciate this opportunity to provide article-by-article…
On September 25, 2025, Perrigo v. U.S. was decided, marking a significant win for the taxpayer, particularly in the Court’s finding regarding economic substance and risks. The Federal Judge in the…
In my Kluwer article of February 11, 2023, The 3M Decision: Did Treasury or Congress Overturn Past Jurisprudence? I predicted that the Eighth Circuit Court of Appeals would likely overturn the Tax…
Pramod Kumar Siva and William Byrnes of Texas A&M University School of Law’s International Tax Risk Management graduate programIn response to a question from some of our non-U.S.-educated tax law…
By Pramod Kumar Siva and William Byrnes of Texas A&M Law1. Previous Comments, Recommendations, and Policy Analysis to the OECD and UNPramod Kumar Siva and I have been closely following and engaging…
From Pramod Kumar Siva and William Byrnes of Texas A&M University Law's International Tax Risk Management Graduate ProgramRe: Workstream I (Framework Convention), Workstream II (Protocol on Cross…
Coca-Cola announced that it would appeal to the Eleventh Circuit Court of Appeals, based in Atlanta, the Tax Court’s final entered decision of August 2, 2024, in favor of the IRS’ determination of $9…
