Texas A&M University School of Law Professor William Byrnes will speak October 5 at the American Bar Association’s (ABA) Fall Tax meeting in Atlanta, GA.
William Byrnes will debate with a former IRS official, Barbara Mantegani, whether the new BEAT (an alternative minimum tax regime for foreign corporations’ US income) is a treaty override.
Byrnes says, “Barbara and I have flipped a coin for opposite positions on whether the unfavorable treatment of foreign tax credits for BEAT purposes applies in a treaty context?"