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Louisiana Practice, Edited By Henry George Mcmahon. Westpublishing Co., St. Paul, 1939. 2 Vols. Pp. Xviii, 2146. $20.00., Hon. William H. Byrnes Jr., Leon Sarpy Jun 2018

Louisiana Practice, Edited By Henry George Mcmahon. Westpublishing Co., St. Paul, 1939. 2 Vols. Pp. Xviii, 2146. $20.00., Hon. William H. Byrnes Jr., Leon Sarpy

William H. Byrnes

No abstract provided.


How May The United States Leverage Its Fatca Iga Bilateral Process To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments? A Carrot & Stick Policy Proposal, William Byrnes Jun 2018

How May The United States Leverage Its Fatca Iga Bilateral Process To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments? A Carrot & Stick Policy Proposal, William Byrnes

William H. Byrnes

Professor William Byrnes examines whether it is prudent for taxpayers to trust the governments of the 117 countries that scored a fifty or below on Transparency International’s corruption index. The complete information system invoked by the Foreign Account Tax Compliance Act (FATCA) encourages, even prolongs, the bad behavior of black hat governments by providing fuel (financial information) to feed the fire of corruption and suppression of rivals. Professor Byrnes recommends that the United States leverage a “carrot-stick” policy tool to incentivize bad actors to adopt best tax administration practices.


A Review Of The Development Of An Internet Delivered Ll.M Program In The United States, William Byrnes Jun 2018

A Review Of The Development Of An Internet Delivered Ll.M Program In The United States, William Byrnes

William H. Byrnes

This article reviews the development of the first Internet delivered LL.M program (i.e. LL.M. of International Tax and Offshore Financial Centers, the ‘Program’) in the United States.

The paper comprises four sections: In Part 1 the economics reasons for, and logistics considerations of, the Internet delivered Program are addressed. Part 2 reviews the pedagogical approach to legal education employed in the United States, criticisms thereof, and finally examines an emerging pedagogical trend in the United Kingdom. Part 3 reviews the teaching tools employed in the Program International Tax and Offshore Financial Centers, and Part 4 reviews the practical aspects of …


How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes Feb 2017

How May The United States Leverage Fatca To Incentivize Good Tax Administrations Among The World Of Black Hat And Grey Hat Governments?, William H. Byrnes

William H. Byrnes

This Essay serves as a preliminary narrative to examine the serious challenge of Control Firsters’ vision that every jurisdiction should have complete information on all transactions by any taxpayer. The world has many, potentially a majority, of grey hat and black hat governments and tax administrations. One measure of which governments fall into these categories is Transparency International’s corruption index. Of 167 countries ranked by Transparency International for breadth of corruption from one hundred (very clean) to zero (highly corrupt/failed state), only fifty countries ranked above a score of fifty, and only twelve scored above eighty. A question that Control …


Ancient Roman Munificence: The Development Of The Practice And Law Of Charity, William H. Byrnes Iv Jul 2015

Ancient Roman Munificence: The Development Of The Practice And Law Of Charity, William H. Byrnes Iv

William H. Byrnes

This article traces Roman charity from its incipient meager beginnings during Rome’s infancy to the mature legal formula it assumed after intersecting with the Roman emperors and Christianity. During this evolution, charity went from being a haphazard and often accidental private event, to a broad undertaking of public, religious, and legal commitment. Charitable giving within ancient Rome was quite extensive and longstanding, with some obvious differences from the modern definition and practice of the activity.

The main differences can be broken into four key aspects. First, as regards the republican period, Roman charity was invariably given with either political or …


The Private Foundation's Topsy Turvy Road In The American Political Process, William H. Byrnes Iv Jul 2015

The Private Foundation's Topsy Turvy Road In The American Political Process, William H. Byrnes Iv

William H. Byrnes

This article studies this American political debate on the charitable tax exemption from 1864 to 1969, in particular, the debate regarding philanthropic, private foundations. The article's premise is that the debate's core has little evolved since that between the 1850s and 1870s. To create perspective, a short brief of the modern economic significance of the foundation sector follows. Thereafter, the article begins with a review of the preand post-colonial attitudes toward charitable institutions leading up to the 1800s debates, illustrating the incongruity of American policy regarding whether and to what extent to grant charities tax exemption. The 1800s state debates …


Ancient Roman Munificence: The Development Of The Practice And Law Of Charity, William H. Byrnes Iv Jul 2015

Ancient Roman Munificence: The Development Of The Practice And Law Of Charity, William H. Byrnes Iv

William H. Byrnes

This article traces Roman charity from its incipient meager beginnings during Rome’s infancy to the mature legal formula it assumed after intersecting with the Roman emperors and Christianity. During this evolution, charity went from being a haphazard and often accidental private event, to a broad undertaking of public, religious, and legal commitment. Charitable giving within ancient Rome was quite extensive and longstanding, with some obvious differences from the modern definition and practice of the activity.

The main differences can be broken into four key aspects. First, as regards the republican period, Roman charity was invariably given with either political or …


The Private Foundation's Topsy Turvy Road In The American Political Process, William H. Byrnes Iv Jul 2015

The Private Foundation's Topsy Turvy Road In The American Political Process, William H. Byrnes Iv

William H. Byrnes

No abstract provided.


Fatca Compliance Of The Mena Region, William Byrnes May 2015

Fatca Compliance Of The Mena Region, William Byrnes

William H. Byrnes

No abstract provided.


Improvements To Combat Money Laundering And Terrorist Financing: A Comparative View Of Spain And The United States, William Byrnes May 2015

Improvements To Combat Money Laundering And Terrorist Financing: A Comparative View Of Spain And The United States, William Byrnes

William H. Byrnes

No abstract provided.


Basics Of Transfer Pricing For International Practitioners, William Byrnes Apr 2015

Basics Of Transfer Pricing For International Practitioners, William Byrnes

William H. Byrnes

No abstract provided.


Recommended Best Pedagogical Practices For Legal Education Delivered With Distance Learning Technologies, William Byrnes Apr 2015

Recommended Best Pedagogical Practices For Legal Education Delivered With Distance Learning Technologies, William Byrnes

William H. Byrnes

No abstract provided.


Regulatory Impact For Best Practices Of Distance Education, William Byrnes Mar 2015

Regulatory Impact For Best Practices Of Distance Education, William Byrnes

William H. Byrnes

No abstract provided.


Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes Mar 2015

Paradigm Shift Of The Tax Avoidance Concept: A Comparative View, William Byrnes

William H. Byrnes

No abstract provided.


Alternative Pedagogical Practices For Consideration By Instructional Faculty, William Byrnes Feb 2015

Alternative Pedagogical Practices For Consideration By Instructional Faculty, William Byrnes

William H. Byrnes

No abstract provided.


Big Data, Cyber Security, And Exchange Of Information Challenges, William Byrnes Feb 2015

Big Data, Cyber Security, And Exchange Of Information Challenges, William Byrnes

William H. Byrnes

No abstract provided.


The 2015 New Year’S Fatca Update, William Byrnes Jan 2015

The 2015 New Year’S Fatca Update, William Byrnes

William H. Byrnes

No abstract provided.


Exchange Of Information Of Corporate Financials Of Mnes For Addressing Beps, William Byrnes Jan 2015

Exchange Of Information Of Corporate Financials Of Mnes For Addressing Beps, William Byrnes

William H. Byrnes

No abstract provided.


Equivalent Tax Self Certification Under Fatca, Gatca And The Eu Tsd, William Byrnes Nov 2014

Equivalent Tax Self Certification Under Fatca, Gatca And The Eu Tsd, William Byrnes

William H. Byrnes

No abstract provided.


Comparing The Equivalency Of The New Crs, Bba, And Us Ben Owner Reporting Forms, What’S A Financial Institution To Do?, William Byrnes Nov 2014

Comparing The Equivalency Of The New Crs, Bba, And Us Ben Owner Reporting Forms, What’S A Financial Institution To Do?, William Byrnes

William H. Byrnes

No abstract provided.


Big Data And Fatca; Transfer Pricing Update, William Byrnes Sep 2014

Big Data And Fatca; Transfer Pricing Update, William Byrnes

William H. Byrnes

No abstract provided.


Best Practices Report Workshop Leader, William Byrnes Sep 2014

Best Practices Report Workshop Leader, William Byrnes

William H. Byrnes

No abstract provided.


Program Startup And Assessment, William Byrnes Jul 2014

Program Startup And Assessment, William Byrnes

William H. Byrnes

No abstract provided.


Meeting The Demands Of The Substantially Overhauled W-8ben Under New Fatca Rules, William Byrnes Jul 2014

Meeting The Demands Of The Substantially Overhauled W-8ben Under New Fatca Rules, William Byrnes

William H. Byrnes

No abstract provided.


Implementing Treasury And Irs Amendments For Nffes; Determining Ffis And Payee Status; Complying With Igas, Withholding And Reporting Rules, William Byrnes Jun 2014

Implementing Treasury And Irs Amendments For Nffes; Determining Ffis And Payee Status; Complying With Igas, Withholding And Reporting Rules, William Byrnes

William H. Byrnes

No abstract provided.


Exchange Of Information: Fatca, Gatca, Beps, In The Context Of Latin America, William Byrnes May 2014

Exchange Of Information: Fatca, Gatca, Beps, In The Context Of Latin America, William Byrnes

William H. Byrnes

No abstract provided.


Novel Ideas: Literary Agents, Writers, And The Law [Entertainment & Intellectual Property], William Byrnes Apr 2014

Novel Ideas: Literary Agents, Writers, And The Law [Entertainment & Intellectual Property], William Byrnes

William H. Byrnes

No abstract provided.


Burning Issues For International Tax Career Seekers, William Byrnes Apr 2014

Burning Issues For International Tax Career Seekers, William Byrnes

William H. Byrnes

No abstract provided.


Cloning Your Clients, William Byrnes Apr 2014

Cloning Your Clients, William Byrnes

William H. Byrnes

No abstract provided.


Section Chair, Best Practices Report, William Byrnes Mar 2014

Section Chair, Best Practices Report, William Byrnes

William H. Byrnes

No abstract provided.