Winners
2023
First Prize ($5000):
Colin Heath
New York University School of Law
Taxing “Borrow” in “Buy/Borrow/Die”
Faculty Sponsor: Professor Daniel Hemel
Second Prize ($2,500):
Frédéric Ney
Georgetown University Law Center
Could An Inheritance Tax with a Partial Step-Up in Basis at Death be a Compromise?
Faculty Sponsors: Professor Beth Bell and Professor Jon Talisman
(tie) Third Prize ($1,500):
Kaleb Mount
Yale Law School
Rethinking Tracing and Electivity in a Flawed Interest Deduction
Faculty Sponsor: Professor Yair Listokin
(tie) Third Prize ($1,500):
Neil Kelliher
University of Virginia School of Law
Clearly Erroneous: Countering Federal Circuit Courts’ Unjustified and Unnecessary Trend Toward De Novo Review of the Economic Substance Doctrine
Faculty Sponsor: Professor Ethan Yale
2022
First Prize ($5,000):
Danny Hirsch
Yale Law School
The CIC Two-Step and the Future of Litigation Against the IRS
Faculty Sponsor: Professor Michael Graetz
Second Prize ($2,500):
Alexander Stephenson
Northwestern Pritzker School of Law
Stacking the Chips: Qualified Small Business Stock Exclusion
Faculty Sponsor: Professor David Cameron
Third Prize ($1,500):
Likhitha Butchireddygari
Columbia Law School
Eliminating the Tax Benefit from Investing in Police Brutality Bonds
Faculty Sponsor: Professor Alex Raskolnikov
2021
First Prize ($5,000):
Mohanad Salaimi
University of Michigan Law School
Corporate Inversions: Getting on the Tax Reform Train Before It Leaves the Station
Faculty Sponsor: Professor Reuven S. Avi-Yonah
Second Prize ($2,500):
Alexander Pettingell
New York University School of Law
A Machine Learning Approach to the Debt-Equity Multifactor Test
Faculty Sponsor: Professor Mitchell Kane
(tie) Third Prize ($1,500):
Ainsley Tucker
Boston University School of Law
Masquerading Churches: Abusing the Internal Revenue Code to Avoid Financial Transparency
Faculty Sponsor: Professor David I. Walker
(tie) Third Prize ($1,500):
Jeff Gordon
Yale Law School
Taxation at a Distance
Faculty Sponsor: Professor Anne L. Alstott
2020
First Prize ($5,000):
Ryan Bullard
University of North Carolina School of Law
I Am “QOZ,” The Great and Terrible: A Policy Analysis of the Qualified Opportunity Zone Nominations Process
Faculty Sponsor: Professor Leigh Osofsky
Second Prize ($2,500):
Heydon Wardell-Burrus
Harvard Law School
Blending Under A Global Minimum Tax
Faculty Sponsor: Professor Alvin C. Warren, Jr.
Third Prize ($1,500):
Tommy Hoyt
Northwestern Pritzker School of Law
The Syntax of a Sin Tax: Lessons on How to Craft a Sweetened Beverage Tax that Can Stand Up to Industry Resistance
Faculty Sponsor: Professor Sarah Lawsky
Honorable Mentions:
Robert Stephen Earnest
University of Minnesota Law School
Ain’t No Taxing High Enough: Using Land Value Taxation to Combat the Nation’s Rental Affordability Crisis
Faculty Sponsor: Professor Ann Burkhart
Susannah R. Kroeber
Columbia Law School
The Case for Over-withholding Federal Income Tax
Faculty Sponsor: Professor Alex Raskolnikov
2019
First Prize ($5,000)
Christine A. Davis
University of Florida Levin College of Law
More Anti-Simplification: PTI and GILTI After the Tax Cuts and Jobs Act Faculty Sponsor: Prof. Mindy Herzfeld
(Tie) Second Prize ($2,000)
Alexandra Ferrara
New York University School of Law
Incentivizing the Care of Adult Family Members Through a Two-Part Tax Credit
Faculty Sponsor: Prof. Lily Batchelder
(Tie) Second Prize ($2,000)
Mitch L. WerBell V
Alexander Blewett III School of Law at the University of Montana
Muddy Base, Resilient Communities: Continued Justification for Historic Preservation Tax Incentives in the Wake of Political Tribalism
Faculty Sponsor: Prof. Pippa Browde
Honorable Mentions
Christopher Dykzeul
University of California Hastings College of the Law
Turbulent Times at Treasury: Applying the Appointments Clause to IRS Appeals Officers
Faculty Sponsor: Prof. Heather M. Field
Ben Satterthwaite
University of South Carolina
Applying Nash Bargaining Theory to Intangible Property Transfer Pricing
Faculty Sponsor: Prof. Clinton Wallace
2018
First Prize ($5,000):
Colin T. Halpin
Washburn University School of Law
A Step in the Right Direction: The Effects of the Tax Cuts and Jobs Act on the Alternative Minimum Tax and the Need for Further Reform
Faculty Sponsor: Prof. Lori A. McMillan
(Tie) Second Prize ($2,000):
Robert Daily
University of Georgia School of Law
Betting on an Uncertain Future: The Tax Consequences of Large Third-Party Litigation Financing
Faculty Sponsor: Prof. Gregg D. Polsky
Alexandre Marcellesi
NYU School of Law
Interpreting the “Reputation or Skill” Clause in Section 199A: A Fool’s Errand?
Faculty Sponsor: Prof. Lily Batchelder
Honorable Mentions:
Ryan M. Gaylord
The University of Chicago Law School
The Section 4960 Excise Tax on Highly Compensated Employees of Tax-Exempt Organizations: Loopholes and Market Distortion
Faculty Sponsor: Prof. Daniel Hemel
Ryan Kenny
University of Cincinnati
Using the Principles of Tax Salience for Guidance on How to Design A National Carbon Tax to Reduce Carbon Emissions
Faculty Sponsor: Prof. Stephanie Hunter McMahon
2017
First Prize $5,000:
David Berke
Yale Law School
Reworking the Revolution: Treasury Rulemaking & Administrative Law
Faculty Sponsor: Prof. Anne L. Alstott
Second Prize $2,500:
Daniel W. Blum
NYU Law School
Treaty Shopping and its Prevention in a Post-BEPS World
Limitation-on-Benefits, Beneficial Ownership and the Principal Purpose Test:
Evolution, Underlying Rationales and Interrelation
Faculty Sponsor: Prof. H. David Rosenbloom
Third Prize $1,500:
Tara Stark
Antonin Scalia Law School, George Mason University
The Billion-Dollar Question: Is It Time To Treat Profit From the Sale of Broadcasting Rights as Unrelated Business Income
Faculty Sponsor: Prof. Rachelle Holmes Perkins
2016
First Prize $5,000:
Jesse Boretsky
Yale Law School
Redefining a Blurry Line: A Proposal to Reform the Taxation of Pension Fund Business and Investment Income
Faculty Sponsor: Prof. Yair Listokin
Second Prize (tie, $2,000):
Sam Lapin
Temple University Beasley School of Law
Finding Propaganda: How to Stop Grassroots Lobbying Costs From Slipping Through the Cracks of Section 162(e)
Faculty Sponsor: Prof. Alice Abreu
Matthew Swift
The University of Chicago Law School
Between a Rock and a Hard Place: Evaluating the Illinois Retirement Income Exemption
Faculty Sponsor: Prof. Daniel Hemel
2015
First Prize $5,000:
Sienna White
Notre Dame Law School
Cost Sharing Agreements & the Arm’s Length Standard: A Matter of Statutory Interpretation?
Faculty Sponsor: Prof. Lloyd H. Mayer
Second Prize $2,500:
Joseph C. Dugan
Indiana University Maurer School of Law
Compromising Compliance?
The IRS Offer in Compromise Program and Opportunities for Reform
Faculty Sponsor: Prof. Leandra Lederman
Third Prize $1,500:
Steven Ort
University of Texas at Austin School of Law
Tracing Time: How Inversion Transactions Change But Remain Undeterred
Faculty Sponsor: Prof. Calvin Johnson
Honorable Mention:
Carson W. King
University of Illinois College of Law
When Virtual Reality Becomes Real: Taxation of CryptoCurrencies
Faculty Sponsor: Prof. Richard L. Kaplan
2014
The 2014 Competition results are set forth below (no second or third prize awarded):
First Prize (Tie - $4,500 each):
Alex Levy
New York University School of Law
Believing in Life After Loving: IRS Regulation of Tax Preparers
Faculty Sponsor: Prof. David Kamin
Mark C. Westenberger
Washington University in St. Louis School of Law
Tax-Exempt Hospitals and the Community Benefit Standard:
A Flawed Standard and a Way Forward
Faculty Sponsor: Prof. Cheryl D. Block
Honorable Mentions:
Nika Antonikova
University of San Diego
Real Taxes in Virtual Economies: What Does the I.R.S. Say
Faculty Sponsor: Brian Galle
Michael Daly
Georgetown University Law Center
Bound and Gagged: Making the Case for Congress Delegating Tax Policy to the Experts
Faculty Sponsor: Tom Field
2013
First Prize (Tie - $3,750 each):
Kate B. Deal
Georgetown University Law Center
Incentivizing Conservation: Capping Land Trusts' Acceptance of Tax-Preferred Easements to Maximize Overall Conservation Value
Faculty Sponsor: Prof. Ronald A. Pearlman
Franziska Hertal
Columbia Law School
Qui Tam for Tax? Lessons from the States
Faculty Sponsor: Prof. Alex Raskolnikov
Third Prize ($1,500):
Beomjune Kim
New York University School of Law
Reconciling Transfer Pricing with Customs Valuation: How to Bridge the Gap?
Faculty Sponsor: Prof. H. David Rosenbloom
Honorable Mentions:
William G. Cochran
Stanford Law School
Searching for Diamond in the Two-and-Twenty Rough: The Taxation of Carried Interests
Prof. Joseph Bankman
Alex Goodenough
Georgetown University Law Center
Commensurate With Income and the Arm's Length Standard: The Problem of Pricing Intangibles
Prof. David Ernick
2012
First Prize ($5,000):
Christopher R. Wray
University of Notre Dame Law School
On the Road Again: The D.C. Circuit Reinvigorates The Work-Product Doctrine in United States v. Deloitte & Touche
Faculty Sponsor: Prof. Matthew J. Barrett
Second Prize ($2,500):
Philip Sancilio
Columbia Law School
Clarifying (or Is It Codifying?) the “Notably Abstruse:” Step Transactions, Economic Substance, and the Tax Code
Faculty Sponsor: Prof. Alex Raskolnikov
Third Prize ($1,500):
Frank Fagan
University of Pittsburgh School of Law
The Growing Problem with Temporary Provisions in the Tax Code: Not Rent-seeking, Not Investment Uncertainty, But Reelection Strategy
Faculty Sponsor: Prof. David J. Herring
2011
First Prize ($5,000):
Michael Behrens
UCLA School of Law
Citizens United, Tax Policy, and Corporate Governance
Faculty Sponsor: Prof. Steven Bank
Second Prize (tie) ($2,000):
Jacob Dean
University of Cincinnati College of Law
“Do you have that new church app for your iPhone?” Making the Case for a Clearer and Broader Definition of Church Under the Internal Revenue Code
Faculty Sponsor: Prof. Stephanie Hunter McMahon
Second Prize (tie) ($2,000):
Stas Getmanenko
Southern Methodist University School of Law
Consequences of Carried Interest Reform for the Private Investment Industry
Faculty Sponsor: Prof. Christopher Hanna
Honorable Mentions:
Tessa Davis
Florida State University College of Law
Reproducing Value
Faculty Sponsor: Prof. Curtis Bridgeman
Jacob Goldin
Yale Law School
Libertarian Paternalist Meets Tax Policy: Designing Commodity Taxes for Inattentive Consumers
Faculty Sponsor: Prof. Yair Listokin
2010
First Prize ($5,000):
Caroline Waldner
New York University School of Law
In Defense of College Savings Plans: Using 529 Plans to Increase the Impact of Direct Federal Grants for Higher Education to Low- and Moderate- Income Students
Faculty Sponsor: Prof. Lily Batchelder
Second Prize (tie) ($2,000):
Frederick N. Vinson
University of Florida Levin College of Law
Taxation of Unhedged Financial Derivatives Transactions: The Need for Schedularization
Faculty Sponsor: Prof. Martin J. McMahon, Jr.
Second Prize (tie) ($2,000):
Timothy Hisao Shapiro
Stanford Law School
Tax First, Ask Questions Later: Problems Predicting the Effect of Obama’s International Tax Reforms
Faculty Sponsor: Prof. Joseph Bankman
Honorable Mention:
Brian Demeter
Cleveland-Marshall College of Law
Cleveland State University
Faxing the Backstop: Alleviating Pressure on Transfer Pricing of Intangibles by Amending Subpart F
Faculty Sponsor: Prof. Deborah A. Geier
2009
First Place
David J. Warner
New York University School of Law
Sponsor: Prof. Noël B. Cunningham
A Pathway to Fundamental Healthcare Reform?:
The Exclusion from Income for Employer-Sponsored Health Insurance
Second Place
Grace E. Jeon
Northwestern University School of Law
Sponsor: Prof. Charlotte Crane
Loss Recognition Allowed: Target Shareholders Can Now Enjoy
Selective Non-Recognition Treatment in Reorganization Exchanges
Third Place
Michael J. Blinn
Indiana University School of Law
Sponsor: Prof. Ajay Mehrotra
The Behavioral Case for a Value-Added Tax
2008
First Place
Kathryn A. Fuehrmeyer
University of Notre Dame School of Law
Sponsor: Prof. Lloyd H. Mayer
Cutting Out the Middleman: Allowing Onshore Debt-Financed Investments by Tax-Exempt Organizations
Second Place
Andrew D. Appleby
Wake Forest University School of Law
Sponsor: Prof. Joel S. Newman
Ball Busters: How the IRS Should Tax Record-Setting Baseballs and Other Found Property Under the Treasure Trove Regulation
Third Place
Leslie J. Carter
University of Chicago School of Law
Sponsor: Prof. Julie Roin
Blowing the Whistle on Avoiding Use Taxes in Online Purchases
2007
First Place
James Bamberg
University of Florida Levin College of law
Sponsor: Prof. Kristin Gutting
A Different Point of Venue: The Plainer Meaning of Internal Revenue Code Section 7482(b)
Second Place
David Kamin
New York University School of Law
Sponsor: Prof. Lily Batchelder
What's a Progressive Tax Change? Unmasking Hidden Value in Distributional Debates
Third Place
Joshua R. Mourning
Washington University in St. Louis School of Law
Sponsor: Prof. Cheryl D. Block
A Tax Policy Analysis of Congress's Labyrinthine Stock Option Tax Scheme
Honorable Mentions
Lora Cicconi
UCLA School of Law
Sponsor: Prof. Steve Bank
Blaming 162(m) for the Backdating Scandal: Legitimate Concerns or Scapegoating?
Sponsor: Prof. Lily Batchelder
Optimal Property Taxation: An Endowment Tax on Land Value
2006
First Place
Manoj Viswanathan
New York University School of Law
Sponsor: Prof. Lily Batchelder
Sunset Provisions in the Tax Code: A Critical Evaluation and Prescriptions for the Future
Second Place
Markus Ernst
New York University School of Law
Sponsor: Prof. H. David Rosenbloom
Toward a Level Playing Field for Thin Capitalization -- A Comparison Between German and U.S. Approaches
Amandeep S. Grewal
Georgetown University Law Center
Sponsor: Prof. Albert G. Lauber, Jr
Substance Over Form? Phantom Regulations and the Internal Revenue Code
Honorable Mentions
Mark Totten
Yale Law School
Sponsor: Prof. Anthony Kronman
The Politics of Faith: Toward Legislative Revisions of the I.R.C. Prohibition on Political Intervention
Lora Cicconi
UCLA School of Law
Sponsor: Prof. Kirk J. Stark
Competing Goals: Amidst the "Opt-Out" Revolution: An Examination of Gender Based Tax Reform in Light of New data on Female Labor Supply
Deanna Joy Green and Julia Conn
Boston University School of Law
Sponsor: Prof. Alan L. Feld
Crafting a Post-CUNO Course for Constitutional State Tax Incentives
2005
First Place
Chloe A. Burnett
New York University School of Law
Sponsor: Prof. H. David Rosenbloom
From the CFC Babel to the Round Table: Replacing Multiple CFC Regimes With a Collective, Targeted Attribution System
Second Place
Celia Whitaker
Yale Law School
Sponsor: Prof. Michael J. Graetz
How to Build a Bridge: Eliminating the Book-Tax Accounting Gap
Third Place
Andrew L. Grossman
New York University School of Law
Sponsor: Prof. Deborah Schenk
Examining the Education Provisions of the Tax Code
Honorable Mentions
Lindsay H. Rubel
Washington & Lee School of Law
Sponsor: Prof. Harlan Beckley
Complexity, Regressivity, and Income Disparity: Self-defeating Aspects of the Earned Income Tax Credit.
Joshua Mishkin
University of Maryland School of Law
Sponsor: Prof. Robert I. Keller
The State of Integration in a Partial Integration State: A Discussion of Corporate Tax Integration, President Bush's Fiscal 2004 year Proposals, and The Jobs and Growth Tax Relief Reconciliation Act of 2003
Natalya Teplitsky
Hofstra University School of Law
Sponsor:Prof. Linda Galler
Contingent Liability Tax Shelters: Past, Present and No Future
Chin-Chin Yap (Ms.)
Georgetown University Law Center
Sponsor: Prof. Ethan Yale
The Tax Shelter Games
2004
First Place
Robert Yablon
Yale Law School
Sponsor: Prof. Michael Graetz
Defying Expectations: State Responses to the Repeal of the State Death Tax Credit
Second Place
Gabriel S. Garcia
UC Berkley - Boalt Hall School of Law
Sponsor: Prof. Eric P. Rakowski
Server Location v. Contention Creation: An Analysis of Place of Service Rules in International Taxation of E-Commerce
Third Place
Elizabeth Chorvat
University of Virginia School of Law
Sponsor: Prof. Edwin Cohen
A Thinly-veiled Mischief: The Case Against Tax Harmonization
Rebecca M. Kysar
Yale Law School
In Critique of Sunset Provisions in the Tax Code
Honorable Mentions
Leeanna Izuel
Loyola Law School
Sponsor: Prof. Theodore Seto
Rules vs. Standards: Revisiting the Dutch Boy's Success
Elena Tsaneva
Brooklyn Law School
Sponsor: Prof. Harry Ballan
Transfer Pricing in the World of Services and Intangibles - A New Challenge to Preserving the Corporate Tax Base
2003
First Place
Sagit Leviner
The University of Michigan School of Law
Sponsor: Prof. Kyle Logue
1. Affordable Housing: The Role of the Low Income Housing Tax Credit Program -- A Contemporary Assessment
2. The Vision of a Good Society and the Tax System or Tax Justice Revisits
Second Place
Trever Asam
Duke Law School
Sponsor: Prof. Richard Schmalbeck
Bob Jones Goes to Hawaii: Charitable Institutions, the Mancari Doctrine, and Hawaiians-Only Education at the Kamehameha Schools
Third Place
Mindy Herzfeld
Georgetown University Law Center
Sponsor: Prof. Clarissa Potter
The Intersection of U.S. Tax Policy and U.S. Foreign Policy
Honorable Mentions
Michelle Jewett
Harvard Law School
Sponsor: Prof. Bernard Wolfman
Stock Options Used as Executive Compensation: Current Tax and Accounting Treatment, Possible Reform, and Congressional Proposals to Align the Two
Alexis A. Olson
University of Florida Fredric G. Levin College of Law
Sponsor: Prof. Martin J. McMahon, Jr
1. Are Subchapter C sections obviated when corporations no longer have an incentive to distribute earnings as capital gains?
2. The effect of the excludable dividend proposal on Subchapter C
2002
First Place
Mark E. Erwin
New York University School of Law
Sponsor: Prof. Linda Sugin
A Policy Analysis and Critique of the Joint Committee on Taxation's Simplification Study
Second Place
Amy Beth Erenrich
Harvard Law School
Sponsor: Alvin C. Warren
The Taxation of Equity-Linked Debt Instruments
Steven Quiring
University of Texas Law School
Sponsor: Prof. Calvin H. Johnson
Section 357(c) and the Elusive Basis of the Issuer's Note
Elena Romanova
New York University School of Law
Sponsor: Prof. Deborah Schenk
Cancellation of Nonmember Indebtedness Within Consolidated Groups: Implications of United Dominion Indus., Inc. v. U.S.
Honorable Mentions
Delphine G. Pioffret
University of Richmond, T.C. Williams School of Law
Sponsor: Prof. Mary L. Heen
The WTO Appellate Body's Ruling Against U.S. Export-Contingent Tax Subsidies: History of the Dispute, Arguments of the Parties and Consequences of the Decision
Allison E. Wielobob
Georgetown University Law Center
Sponsor: Prof. Clarissa Potter
U.S. and International Taxation of Stock Options – An Overview of the Thorny Issues
Emerson Moser
Wake Forest University School of Law
Sponsor: Prof. Joel S. Newman
The Victims of Terrorism Tax Relief Act of 2001: How 4 Planes, 4,000 Casualties and 435 Representatives Created a Tax Policy Disaster
2001
First Place
Shawn P. Travis
Harvard Law School
Sponsor: Prof. Alvin C. Warren, Jr.
The Accelerated & Uneconomic Bearing of Tax Burdens By Mutual Fund Shareholders
Second Place
Damian Laurey
University of Virginia
Sponsor: Prof. George K. Yin
Untangling the Stock Option Cost Sharing Loophole
Third Place
Janine Shissler
Yale Law School
Sponsor: Prof. Michael J. Graetz
The Simplification Potential of Adopting an Exemption System for Foreign Source Active Business Income
Honorable Mentions
Annie Ligman
University of San Diego
Sponsor: Prof. Lester B. Snyder
The Tax Treatment of Stock Option Compensation Under the Haig-Simon and Mark-to-Market Theories of Income Measurement
Michael M. Lloyd
University of Maryland
Sponsor: Prof. Daniel S. Goldberg
A Tale of Two Theories: Should Section 1041 Trump the Assignment of Income Doctrine?
Ruth Mason
Harvard Law School
Sponsor: Prof. Bernard Wolfman
Spinning Section 355(e): Will Treasury Interpret the Anti-Morris Trust Provision According to Its Purpose?