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@professorwilliambyrnes
Tax Facts Intelligence (July 30 - Aug 5)
Weekly newsletter of Prof. William Byrnes & Robert Bloink of Texas A&M Law’s wealth management program: full articles available on ThinkAdvisor TaxFacts (https://www.thinkadvisor.com/tax-facts/) 1. IRS Fixes 1035 Life Insurance Exchange Trap: IRC Section 1035 allows taxpayers to trade life insurance contracts and annuities for new contracts without creating an immediate taxable event. We discuss…
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Is Art an Alternative Investment that Beats Inflation? What Reliable Data Shows Over the Short and Long Term.
By Professor William Byrnes, Texas A&M University School of Law, and founder of the Wealth Management graduate program. This is the first part of a multi-part series regarding art from the perspective of investment and taxation. For generations, high-net-worth families have viewed art collections as something to personally admire and display for social or status reasons. But the value of art as…
Supreme Court Nulls the Trump Tariffs
On February 20, 2026, the U.S. Supreme Court in Learning Resources, Inc. v. Trump[1] (avaialble on Lexis here) provided its 6-3 majority answer in a 170-page, multi-part decision to the question whether the International Emergency Economic Powers Act’s (‘IEEPA’) authorization to ‘regulate…importation’ provides the executive branch broad power to impose tariffs?[2] And if so, under what…
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UN Tax Committee Confronts New Challenges from AI to Health Taxes
By Pramod Kumar Siva and William Byrnes of Texas A&M Law 1. Previous Comments, Recommendations, and Policy Analysis to the OECD and UN Pramod Kumar Siva and I have been closely following and engaging via comments and attendance, with the post-BEPS international tax initiatives of the OECD, the United Nations, and U.S. responses (as have our most esteemed Texas A&M faculty colleagues…
My Cambridge Plenary Presentation: Why is $5.5 Trillion of U.S. AUM Exempt from the BSA’s AML, CIP & SAR Rules?
William_Byrnes_FINCEN_Revokes_BSA_for_Investment_Advisors_4 Sept_2025Download primary sources and data referred to within my presentation include: Foreign Portfolio Holdings of U.S. Securities end of 2Q 2024 (published by U.S. Treasury April 2025) SEC monthly information and data of Registered Investment Advisers and Exempt Reporting Advisers FinCEN revised final rule link (December 2024) and…
International Tax & Transfer Pricing Certificates or LL.M. / Master Legal Studies at Texas A&M
International Tax & Transfer Pricing (non-degree) Certificates or LL.M. (for law graduates) / Master Legal Studies (for accountants, economists, and financial professionals) are designed for an in-depth study of tax risk management. Sample of Courses (see graduate programs catalog) Transfer Pricing l – Methods, Econometrics, and Tangibles – January start Transfer Pricing II – Services and…
Is bringing investment advisors with the scope of KYC and SAR rules too much or much needed?
Over $5.5 trillion of assets under management (AUM) by U.S. investment advisors is exempt from customer identification program (CIP) obligations, customer due diligence (CDD) requirements, and the filing of suspicious activity reports (SARs), which are essential aspects of the federal defense mechanism against criminal and terrorist organizations. Why is this so? Because the U.S. money laundering…
Who is Responsible for Increasing Health Care Costs?
Professor William Byrnes, Texas A&M University School of Law, Risk Management Graduate Program. Based on my recent debate with Robert Bloink, “Should the Tax Bill Expand HSAs?”, a reader asked me to comment on both parties’ failure to address the central issue of costs regarding the sustainability of Medicare and Medicaid. This is my part one response, focused primarily on physicians. I plan to…
How May Chevron’s overruling Impact Treasury Regulations?
The U.S. Supreme Court today issued its expected overruling of the Chevron doctrine, which has been relied upon in 70 past Supreme Court decisions and approximately 17,000 in the Appellate and District courts.[1] Brief Overview of the Chevron Doctrine In a landmark unanimous decision in 1984, the Supreme Court established the Chevron doctrine. Only six justices participated due to the recusal…
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Supreme Court holds constitutional tax on U.S. shareholders for imputed undistributed income of foreign corporations but limits holdings' impact on future taxes.
At the end of 2017, Congress passed a once-off Mandatory Repatriation Tax (the “MRT”) of 8 to 15.5 percent of the undistributed total accumulated income of American-controlled foreign corporations over the past thirty years (since 1987).[1] This accumulated income, if distributed, would be taxed in the hands of the American shareholders. However, because Congress cannot force a foreign…
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Texas, California, and New York expenditure, debt, tax burden for 2024
I am contrasting state and locality living for 2025 updates. I am sharing what I found for Texas, California, and New York state and local budget expenditures, followed by accumulated state and locality debts for FY2024. Then, I contrast the total income tax and the property tax for living in Dallas, Fairmont-Los Angeles, and Nassau County. There is no particular reason for these three locals;…
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Texas A&M University Law Professor Honored with Distinguished Achievement Award
Professor William Byrnes of Texas A&M University School of Law received the Association of Former Students Distinguished Achievement Award for Professional Development, which includes a monetary gift and an engraved gold Texas A&M watch. Texas A&M President Mark Welch stated In his letter to Professor Byrnes: “The Distinguished Achievement Award, generously funded by The Association of Former…
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Who should inherit a $750,000 retirement account: a former romantic partner of 25 years ago named as a beneficiary back then or the surviving family and current romantic partner of the past 25 years?
Howdy! I’m Professor William Byrnes of Texas A&M University School of Law, where I founded the graduate program for wealth management. Today, I want to share with you a cautionary tale about estate planning, specifically focusing on retirement accounts, designated beneficiaries, and former romantic partners. Three-Part Discussion Overview: Misconceptions about Retirement Accounts and Wills:…
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Beware the Roth Conversion Penalty Trap
Robert Bloink and Prof. William Byrnes’ (Texas A&M Law) weekly Tax Facts Intelligence strategy newsletter for financial advisors is available via the Tax Facts app or search.TaxFactsOnline.com
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Byrnes and Bloink's Tax Facts Intelligence July 2023 wealth building strategy articles
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International Tax & Transfer Pricing Certificates or Master Degree at Texas A&M
The International Tax Certificate and Master Degree are designed for international tax professionals (lawyers, accountants, economists, and finance) for an in-depth study of tax risk management. Degree candidates are exposed to (i) international tax laws, regulations, and policies in the international tax risk management field, (ii) technology and tax data management, and (iii) weekly practice…
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TaxFacts Intelligence: December 29, 2022
TaxFacts Intelligence: December 29, 2022
The Texas A&M Master and LL.M. programs (e.g. international tax, transfer pricing, wealth management, or risk management) are accepting applications from financial professionals and from lawyers. Over 850 enrolled, the enrollment for a course’s section is kept to between 20 and a maximum of 30 so that each student receives meaningful feedback throughout the course from the full-time academic…
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