YORK - MIAMI - LA - HONG KONG - DUBAI - SINGAPORE - BEIJING
Syllabus for Principles of International
Taxation - LLM101
William H Byrnes, IV, Esq was the director
of the validated distance learning tax LLM for the last
8 years, and before accepting his previous associate professorship
of law in the US, was formerly an associate director of
international taxation at Coopers & Lybrand, South Africa
1993 with the support of the Tax Academy of the IBFD and
the Law faculty at the University of Amsterdam, Professor
Byrnes outlined the curriculum of the tax program as well
as the drafting and collection process for its materials.
Professor Byrnes first taught the tax program residentially
in 1994 (in South Africa). Students from that original
year have now become instructors in the program, such as
Kithsri DeSilva of the New Zealand Revenue Service and Basil
Newton of PricewaterhouseCoopers. Also, the original
instructors, such as Daan Ribbens and Roy Rohatgi continue
teaching courses in the program today.
Byrnes created the present online program in 1996 with the
support of Walters Kluwer Academic Publishers. The
American Bar Association first acquiesced to the program's
United States online delivery in 1998. In 2000, the
program found its new home at St Thomas University School
of Law in Miami. Since 2007, these may be available to special
Byrnes is a US attorney and is the creator and instructor
for EuroMoney's ™ international tax training and e-commerce
programs, holding courses in London, Hong Kong, Singapore,
Miami, Portugal, Cyprus, amongst other places.
was a consultant editor for Kluwer Law & Tax Publishers
(London) for many years before he was a consultant editor
for Richmond Law & Tax, for the production of a complete
international tax library E-book series.
He is Chief Author of the forthcoming loose-leaf
series, Offshore Trusts & Companies Laws, Analysis
and Tax Planning and is Chief-Author of Electronic
Commerce: Law, Tax & Business, as well as Anti-Money
also worked on Kluwer’s internet database of tax materials
as well as the International Fiscal Association’s
(IFA) methodology of categorization of taxation.
Thomson Tax, he is the author for the US Chapter for International
Tax Systems and Planning Techniques, a series by Roy Saunders
and Miles Dean.
Before that, he was the Associate Editor to Walter
Diamond of the Diamond loose-leaf series: Tax
and Trade Briefs. Matthew Bender (New York).
1995 he co-authored South African Tax Reform as well
as served as managing editor of the Exchange Control
Encyclopaedia (taken over by Butterworths).
is a Visiting Professor of International Taxation to the
Masters program of the Faculty of Commerce, Law, and Management
at the University of the Witwatersrand (Johannesburg) and
before that was the coordinator and lecturer of the International
Tax Masters of Commerce program at RAU (Johannesburg).
was granted the title of Fellow (International Taxation)
at the International Bureau of Fiscal Documentation (IBFD,
Amsterdam) and has advised governments of developing economies
on tax policies. He
holds a degree in Political Economics of the law track of
the Murphy Institute of Tulane University and a Juris Doctorate
from Loyola University School of Law.
His LL.M., specialized in European Business and Taxation,
is from the University of Amsterdam Faculty of Law and the
has consulted for, and trained, publicly listed multinationals,
and developed corporate and high net wealth individual tax
efficient strategies for business operations and life style.
Start Date: every Fall
of International Taxation (“PIT”) is a primer
for the concentration of International Taxation.
This course and its concentration provide much more
than a comparative overview of the tax law and accounting
of significant trade nations.
This course is designed for two groups of professionals
with generally opposing aims: the group of in-house tax
counsels of a multinational enterprise (“MNE”),
accounting firm, or law firm whose focus is achieving the
minimum global effective rate of taxation for an MNE and
the group of revenue and treasury officials that seek to
maximize tax collections with consideration for national
This course starts with two weeks of political economic
policy considerations that lead into questions concerning
the drafting of national revenue law.
The following two weeks presents an overview of global
tax planning, examining sources of law (i.e. public international
law, bilateral and multilateral tax treaties, the European
Union, trade organizations) and the basic global tax diagnostic. The next five weeks examines the exercise of fiscal jurisdiction
and the determination of the taxable income for natural
persons, corporate entities, business operations, and types
of income (i.e. services, interest, capital gains) and also
how tax treaties effect the exercise of fiscal jurisdiction
and limit the imposition of tax.
The following five weeks concern issues associated
with multiple jurisdictions exercising taxation on persons,
business operations, income and losses, and how jurisdictions
may mitigate this double taxation (and double dipping of
deductions and losses) under local law and also using tax
the course turns back to both the MNE’s diagnostic
and the original political economic discussion, this time
also addressing inflationary and other complex intermediate
developing economy issues.
course is primarily taught by Professor William H Byrnes
with the assistance of Professor Brian Arnold (University
of Western Ontario).
Besides the final examination that includes writing
two client memos based on fact questions, this course uses
common law case examination, complex case studies, personal
and group assignments to assess the students.
Generally this course is taken concurrently with
familiarize you with the electronic campus
introduce you to electronic study
introduce you to the institutions and databases that
are relevant to your study and to your professional career
develop skills, using electronic resources supported
by paper resources, to conduct efficient, effective, and
thorough international tax research
the writing methodology expected from you by your professors
present the general legal principles applicable to
present the parameters that guide your study
present the tools of tax planning
From Your Instructor
let me thank you for enrolling in this new and exciting
type of education delivery.
As you know by now, we are the trend setters by offering
the first developed online LLM program.
learning is uniquely appropriate in this field.
Let me tell you about your class.
all of you (as you will learn from your communication in
the conferencing) are working professionals in some area
of the industry, such as banking, tax planning, both in-house
and for firms, and corporate secretarial work.
live equally spread out amongst the regions of the globe.
of you travel for your work.
Some of you spend an average of a week a month away
from your home office.
of you work more than 50 hours a week, while many work more
than 60 hours a week.
you imagine trying to put even half of us in a classroom
in some city at the same time every week for three months?
together we embark upon this new, convenient, and effective
way of learning.
to expect from this course
sixteen week course is different from the other program
courses in that it starts out showing you how to learn using
this new medium of education delivery.
starts out with some basic information that may seem to
simple for some of you.
Read through it anyway.
course is the foundation course to study in the program.
It will give you the necessary tools to undertake
your study in the program.
Also, it will introduce you to each other (your colleagues
for the rest of your study) and allow you the chance to
could have allowed you to learn these things along the way.
But, many of you will think that because you are
learning from behind a computer screen, that you are alone
in your studies or that others have access to better research
materials than yourself.
This is not true.
my experience at Coopers & Lybrand (now PricewaterhouseCoopers),
I did not meet many of the worldwide Coopers persons that
I spoke with by email through our international Lotus Notes
I knew that someone from the firm was always out in the
cyber network to assist with my thinking process.
And in order to keep up with present discussions
of US tax issues, I subscribed and participated to the email
tax mailing lists of the ABA and Tax Analysts while consulting
do I begin?
will join the class and myself in the cyber "classroom"
by hitting the hyper link in Module 1 (your first week’s
study material and assignments) of the study guide.
Thus, when you are ready to start, just open Module
1 in the study guide and follow the instructions.
to see you there.
William H Byrnes, IV
guide Module 1: Getting to know your University
guide Module 2
guide Module 3
is Intl. Taxation?
guide Module 4
to international tax
is Intl. Taxation?
to Tax-- Intro
guide Module 5
1-19 (Residence Taxation)
Taxation of Aliens Under International Law
and Practice of Legislative Fiscal Jurisdiction
guide Module 6
Incentives for Developing Countries and International
of the study
residence under domestic law
Fiscal Residence and Absence of Fiscal Residence
of Fiscal Residence
of fiscal residence in double tax agreements
residence and third countries
under domestic law and residence under double tax
and tax avoidance
Guide Module 7
to study text material
and comparison chart
Items of Income
guide Module 8
primary categories of international tax planning
of tax rate
guide Module 9
for double taxation
guide of Module 10
tax conflict rules
versus international tax dimension
guide Module 11
Credits and planning
Double Taxation and Tax Credits
Juridical Double Taxation of Inc.
guide Module 12
Taxation and Tax Credits
Logic of Tax
Taxation - for investment income
guide of Module 13
of investment income
Treatment of Corporate Losses
guide of Module 14
and tax policy
in Hyperinflationary Economies
of Multinational Corporations
guide of Module 15
- Comparative corporate tax
Aspects of International Trade Law
guide of Module 16
reading the materials for a module, it is time to join the
class discussion in the cyber classroom.
participation in the cyber classroom is required absent
In this course, 20% of the course final grade will
be comprised of a participation grade.
grades will be based upon your
submitting the assignments in a timely manner,
demonstration of preparation through the weekly
discussion of topics, problems or issues.
in the cyber classroom will be assessed by
evaluating your informed questions,
comment and responses to other student’s questions
and analysis of problems (i.e. take part in conference
discussions through meaningful input for all of us involved
in the course).
if I do not participate every week?
more that you participate in a meaningful way, the more
of the 20 possible points (of the 100 that form your course
grade) that you pick up.
Total lack of participation means that you start
your testing and exams down 20 points (at 80) which would
make it exceedingly difficult to pass the course with a
may not tune in every week in a meaningful way (our clients
always come first – right?)
Guide your participation as follows:
always turn in requested assignments (minus half-point
for each day of a late assignment
in 14 weeks, you should come up with 14 useful
comments or responses, maybe three comments one week
and none for two weeks, but in the end you should have
an average of one per week
assignments count as a comment, so if you have
an assignment do, count it against that week’s
conference classroom web-based system allows for easy communication
with and among students and faculty in an interactive format
that simulates traditional classroom discussions.
what is the “cyber” classroom?
in the conference classroom is asynchronous (simultaneous
participation is not necessary).
Thus, you are not locked to being at a computer at
a certain time (a good thing considering the times zones
your class traverses).
may participate in the classroom at any time from any computer
hooked up to the web.
Thus, if you are waiting for several hours to transfer
flights at the airport, walk into the airport business center,
pull up to a computer, and enter the classroom.
The same goes for downtime at a hotel.
And most world cities have easy to use, inexpensive,
internet cafes, and also internet access in the various
conference classroom interface allows a high level of interaction
and flexibility: you can post text, graphics, HTML and internet
links in the classroom, email your instructor directly or
experience is that the postings in the cyber classroom social
corner become very friendly, with students posting new born
baby pictures or not-so-glamorous pictures from the office
enter the conference classroom you must have a password.
The password is given to you when you register for
the course. Do
not share it with anyone.
When your password accesses the conference classroom,
the postings associated with it are automatically credited
to your name – and thus are figured into your participation
grade (for better or for worse).
all the courses, we have much material to cover in just
14 weeks. To
make it manageable, the text material is organized into
A module should require about 5 to 20 hours of your
time to study, outline, learn, and complete (it just depends…).
The modules are further split into topics as appropriate
to separate different topics.
module consists of text material and complementary study
guide material. The
study guide is both delivered as colloquial text in a book
and as colloquial written lectures in the cyber classroom.
the study guide hyperlinks to web pages outside the program
in order to access supplementary text material or suggested
will begin the course each week by accessing the weekly
study guide module (from the hyperlink in the syllabus)
and from there reading the required text material.
the cyber classroom to receive my informal, social introduction