TJSL Associate Dean William Byrnes has been appointed by LexisNexis as the primary author of its Practical Guide to U.S. Transfer Pricing, his sixth Lexis title.
“I am honored that LexisNexis chose me to take over this 28 chapter publication established by the renowned Robert Cole,” said Dean Byrnes. “But I was saddened by the passing of Bob, who in his 81 years, made such a tremendous impact in the field international taxation. He was one of the icons of international taxation, in the league of Stanley Surrey and Walter Diamond. In the early seventies he served as the first international tax counsel of the IRS and just last year rejoined Treasury’s transfer pricing department.”
Dean Byrnes responded to the question of whom he plans to work with on this book this way: “I initially sought industry input with my own faculty like Dr. Salis and Professor Correa regarding its thoughts on which issues and cases from this past year will be the critical pain points for tax risk management counsel. Then I sought more advice on emerging issues that may crop up the coming year.
“I am fortunate to be working on this Lexis book with the industry’s leading transfer pricing professionals, from firms like DLA Piper, Alston, Covington, Pillsbury, Jones Day, McDermott, Duff & Phelps, Miller Chevalier, PwC, E&Y, and multinational companies like Temenos and Vertex.”
Dean Byrnes further explained, “Transfer Pricing is one of the most complex and robust areas of tax regulation in the United States and globally. The big ticket cases, ones with over a half-billion dollar adjustment, are almost always transfer pricing. And with the renewed government focus on this topic the past year, transfer pricing audits will both increase in number and in actions taken, not just for the IRS, but most countries’ revenue authorities.”
Reflecting upon his studies, Dean Byrnes said: “This is an exciting opportunity to build upon my original Fellowship dissertation research. In the early nineties I spent three years for my Fellowship at the IBFD focused on analyzing the subject of transfer pricing, especially from an economic and trade perspective. During that Fellowship, I developed a transfer pricing course that I taught the first time in Johannesburg in 1994.
“One of my initial students, Kithsri Da Silva, who became a professor in my online international tax program in 1998, developed a substantial career in the field, albeit as a government revenue officer. Another alumnus from the initial online offering of the course, Dr. George Salis, is now a preeminent expert and economist in the field, working with Vertex.”
Finally, Dean Byrnes added, “The transfer pricing course that I have taught since 1994 is unique, based on a developing case study approach. Now with an international tax faculty of George Salis (Vertex), Kithsri Da Silva (New Zealand Revenue), Debora de Souza (Temenos), Ednaldo Silva (RoyaltyStat) the slate of transfer pricing courses has developed a global audience. Our case studies are intensive, law and economic focused, and highly practical for tax counsel.
“Over the next couple years, I can see expanding the publication to a second volume to include analysis of the transfer pricing rules of countries active in international trade.”
William Byrnes recently was the primary author of the LexisNexis Guide to FATCA Compliance, published earlier this year. See Professor Byrnes’ Book on LexisNexis Website