Diamond School of Law

LL.M. Program

Syllabus for Offshore Financial Centers

Spring Semester only – 16 weeks and an exam week

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 at St Thomas University School of Law (Miami), 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 permanent home at St Thomas University School of Law in Miami.

Technology issues:

v      Blackboard – email or call your (local) Lexis numbers

v      Proxy service – problem getting the proxy service to work with your computer- email or call the OIT office (helpdesk@stu.edu);

v      Problem accessing a database, email or call the law library, and if that does not work, then the Head Librarian Professor Gordon Russell (grussell@stu.edu).

v      Forgot your Westlaw or Lexis password: email taxadmin@stu.edu 

v      Problem accessing Westlaw, Lexis, other database – you need to contact the database provider directly with your password and student id number.

If all else fails, then I am the acting 24/7/365 support, so call me on my cell phone.