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2020-2021 Academic Year
International Tax & Tax Treaties I: Residency Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits
| Week 1 |
Aug 24 Domestic Tax Rights; Double Taxation; Tax Treaty Allocation Of Tax Rights |
| Week 2 |
Aug 31 Types Of Taxes; Tax Treaty Interpretation |
| Week 3 |
Sept 7 Tax Jurisdiction Over Persons, Tax Treaty Interpretation |
| Week 4 |
Sept 14 Tax Jurisdiction of Corporations; Tax Treaty Interpretation & Application |
| Week 5 |
Sept 21 Tax Jurisdiction of Entities |
| Week 6 |
Sept 28 U.S. Tax Reform / Pillar II |
| Week 7 |
capstone of tax data analytics and technology |
International Tax Risk Management & Domestic Systems (Inbound)
| Week 1 |
Aug 24 national tax systems in general and inbound diagnostic Dr. Susana Bokobo, former global tax policy director Repsol |
| Week 2 |
Aug 31 Manuel Tron Mexico as an inbound diagnostic case study (President Emeritus, International Fiscal Association) |
| Week 3 |
Sept 7 Elis Prendergast (KPMG) |
| Week 4 |
Sept 14 Carson Le (KPMG) |
| Week 5 |
Sept 21 Dr. Maji Rhee (Waseda) Japan/Korea as inbound case studies |
| Week 6 |
Sept 28 Domestic Compliance Risk Matrix Hafiz Choudhury |
| Week 7 |
capstone of tax data analytics and technology for inbound domestic tax risk management |
International Tax & Tax Treaties II: Source Dr. Bruno Da Silva (Loyens & Loeff), and William Byrnes (TAMU) 3 credits
| Week 1 |
Oct 12 Tax of Business Income (PE, Nexus) |
| Week 2 |
Oct 19 Tax of Investment Income |
| Week 3 |
Oct 26 Taxation of Services and Employment Income (including DST) |
| Week 4 |
Nov 2 Double Taxation and Tax Credits |
| Week 5 |
Nov 9 Tax Accounting |
| Week 6 |
Nov 16 Introduction to Management of Tax and Data |
| Week 7 |
capstone of tax data analytics and technology |
International Tax Risk Management II (Data, Analytics & Technology) 3 credits
| Week 1 |
Oct 12 Manufacturing I Dr. Niraja Srinivasan Pillar 1 (Dell Global Tax) |
| Week 2 |
Oct 19 Manufacturing II (DEMPE & Supply Chain) Niraja |
| Week 3 |
Oct 26 Manufacturing III (Customs) Niraja |
| Week 4 |
Nov 2 Tax of Patents / Technology, Dr. Brigitte Muehlmann (Daylight time ends, Wednesday and Sunday at 8am Central Standard Dallas time zone) |
| Week 5 |
Nov 9 Tax Risk & Tax Technology, Dr. Brigitte Muehlmann |
| Week 6 |
Nov 16 Tax Risk & Tax Technology, Dr. Brigitte Muehlmann |
| Week 7 |
capstone of tax data analytics and technology for global tax risk management |
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Spring 2021* (Jan 10 – April 26, 2020 repeats 2021)
U.S. Tax Risk Management (Data, Analytics & Technology) 3 credits
| Week 1 |
January 11, 2021 Outbound / FDII Melissa Muhammad (IRS LB&I) |
| Week 2 |
January 18, 2021 Inbound / BEAT Melissa Muhammad |
| Week 3 |
January 25, 2021 [check the box] Form 1120 Documentation: Neelu Mehrotra: EY |
| Week 4 |
February 1, 2021 [Subpart F & GILTI, PTEP ] Form 5471 Documentation: Neelu Mehrotra: EY |
| Week 5 |
February 8, 2021 M&A or topic and Neelu Mehrotra: EY |
| Week 6 |
February 15, 2021 FTCs; wrap-up: Melissa Muhammad |
| Week 7 |
Capstone of tax data analytics and technology for U.S. tax risk management |
Transfer Pricing Risk Management: Tangibles, Methods, Economics, and Data (William Byrnes)
| Week 1 |
January 11 Arm’s Length Standard (v Formulary Approach) Dr. Bruno Da Silva & William Byrnes |
| Week 2 |
Jan 18 CUP & Comparables Dr. Lorraine Eden |
| Week 3 |
Jan 25 Cost Plus & Resale Minus Dr. George Salis |
| Week 4 |
Feb 1 Comparable Profits Method & TNMM Dr. George Salis |
| Week 5 |
Feb 8 Profit Split Dr. George Salis |
| Week 6 |
Feb 15 Best Method Dr. Lorraine Eden |
E.U. Tax Risk Management 3 credits
| Week 1 |
March 1, 2021 General Framework & Fundamental Freedoms |
| Week 2 |
March 8, 2021 P/S + Interest / Royalty |
| Week 3 |
March 22, 2021 M&A directive |
| Week 4 |
March 29, 2021 Cross-Border Losses – Dr. Bruno Da Silva |
| Week 5 |
April 5, 2021 Free Movement of Capital (investment funds) Dr. Bruno Da Silva |
| Week 6 |
April 12, 2021 ATAD, DAC 6, Abuse – Dr. Bruno da Silva |
| Week 7 |
capstone of tax data analytics and technology for E.U. tax risk management |
Transfer Pricing Risk Management: Intangibles and Services (William Byrnes)
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FATCA, CRS, and AEoI (Law, Data, Systems): 3 credits
International Tax Risk Management I (Data, Analytics & Technology) 3 credits
* all dates and times subject to change
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This program is fully accredited by the Southern Association of Colleges and Schools Commission on Colleges and has obtained acquiescence from the American Bar Association (ABA).