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Syllabus
for Offshore
Financial Centers
- LLM 104
I.
COURSE DESCRIPTION
This
global tax planning course is focuses on the at least 5
trillion US dollars that most reliable sources (IRS, Scotland
Yard, IMF, World Bank, OECD, etc) report that flows through
and is managed by firms in offshore financial centers. Those
5 trillion dollars represents approximately half the world’s
money supply. We take an in-depth comparative analysis
of some of the best known offshore jurisdictions from the
viewpoint of the planner, the client, and the Revenue. You
will also learn the many effective uses of offshore structures.
The topics include due diligence; offshore planning structures
such as asset protection trusts and foreign holding companies;
planning techniques [e.g., back-to-back finance, licensing
agreements, cross-border double dip leasing; corporate inversion
planning}; comparative regional and jurisdictional analysis
[e.g., which jurisdiction to use for a particular goal];
multinational offshore operations [e.g., treasury management];
offshore vehicle strategy such an re-insurance and private
banking; maintaining an active offshore database; licensing
for offshore service providers and trustees amongst other
topics. This course is taught by Professor William Byrnes
and also uses guest lecturers.
3 credits
required course for international concentration no prerequisites
but beginners should generally take international tax and
tax treaties first.
Instructor:
William
H Byrnes, IV, Esq.; LL.M. (European Tax); Fellow
(Int’l Tax)
Associate
Professor,
Director,
LLM program
office
: +1 305 668-3260
mobile:
+1 786 271 5202
email:
wbyrnes@stu.edu
Graduate
Tax program
Professor
William H Byrnes, IV, Esq is the director of the
distance learning tax LLM Program 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 (now PricewaterhouseCoopers).
Program history
In
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.
Professor
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 home at St Thomas University School of
Law in Miami. Since May 2007, these courses can be
made available for the first time to Fortune 500 companies
and executives.
LLM
Online Course Requirements for Certification:
- CWM
Chartered Wealth Manager - Take LLM 131, and LLM200
- CTEP
Chartered Trust & Estate Planner - Take: LLM111 and
LLM 131
- CPM
Chartered Portfolio Manager - Take LLM 222
- CRA
Chartered Risk Manager - Take LLM106 and 110
- CAM
- Chartered Asset Manager - Take LLM 104 and LLM 105
- CMA
- Chartered Market Analyst - Take LLM 333 (Must of Masters
Degree, JD or CPA)
- RFS
- Registered Financial Specialist - LLM 101 and LLM 102
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