Publications

• Taxing Digital Platforms, 98 Notre Dame L. Rev. (forthcoming 2023) (with Darien Shanske). Accepted, 03/2022.
• Blockchain Initiatives for Tax Administration, 69 UCLA L. Rev. (forthcoming 2022). Accepted, 02/2021.
• A New Framework for Digital Taxation (Part 1), 63 Harv. Int’l L.J. (forthcoming 2022) (with Reuven Avi-Yonah & Karen Sam). Accepted, 10/2021.
• Tax Harmony: The Promise and Pitfalls of The Global Minimum Tax (Part 2), 43 Michigan J. Int’l L. (forthcoming 2022) (with Reuven Avi-Yonah). Accepted, 09/2021.
• Taxing Teleworkers, 55 UC Davis L. Rev. 1149 (2021). Published, 12/2021.
• Digital Services Tax: A Cross-border Variation of the Consumption Tax Debate, 72 Ala. L. Rev. 131 (2020). Published, 11/2020.
• Insulation by Separation: When Dual-Class Stock Met Corporate Spin-offs, 10 UC Irvine L. Rev. 1 (2019) (with Geeyoung Min). Published, 10/2019.
• Engineering Pass-throughs in International Tax: The Case of Private Equity Funds, 56 San Diego L. Rev. 707 (2019). Published, 10/2019.
• Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications, 37 Va. Tax Rev. 421 (2018). Published, 05/2018.
• Considering "Citizenship Taxation": In Defense of FATCA, 20 Florida Tax Review 335 (2017). Published, 05/2017.
• U. S. Offshore Account Enforcement Issues, 16 J. Tax Practice & Procedure 65 (Aug./Sep. 2014) (with Scott D. Michel & Zhanna Ziering). Published, 08/2014.
• Taxation of Indirect Equity Transfers – South Korea, 17 Asia-Pacific Tax Bulletin 140 (with Soo-Jeong Ahn, S.W. Song, and J.E. Chung). Published, 04/2011.
• Major Tax Issues in the Practice of the Financial Transactions – focusing on Syndicated Loan, Public Issuance of the Bonds and the International Financial Transaction, 35 BUSINESS, FINANCE AND LAW 93 (2009). Published, 05/2009.

Presentations

• "Blockchain Initiatives for Tax Administration": Florida State University College of Law Tax Policy Colloquium (virtual, expected spring 2021); National Tax Association Annual Conference (virtual, expected Nov. 2020); University of Oregon School of Law Tax Policy Colloquium (virtual, expected Oct. 2020); 2020 Junior Tax Scholars’ Workshop (University of Utah, virtual, expected fall 2020); Annual Meeting of the Law and Society Association (virtual, expected May 2020); Utah State Bar Tax Section (Salt Lake City, expected Apr. 2020 – rescheduled); 2019 Rocky Mountain Junior Scholars Forum (BYU Law, Nov. 2019); 2019 SEALS Annual Conference (Boca Raton, Jul. 2019). Presentation, Presented, 05/2020.
• "Digital Services Tax: A Cross-Border Variation of the Consumption Tax Debate": UC Irvine School of Law Tax Policy Colloquium (Mar. 2020); BYU Winter Deals Conference (Mar. 2020); AALS Annual Meeting, New Voices in Tax Law & Policy (Washington, D.C., Jan. 2020); National Tax Association Annual Conference (Tampa, expected Nov. 2019); University of Vienna Tax Conference (Vienna, Austria, expected Nov. 2019); BYU Law School Faculty Workshop (expected Nov. 2019); LatCrit 2019 Biennial Conference (Atlanta, expected Oct. 2019); Loyola Law School Tax Policy Colloquium (Los Angeles, expected Oct. 2019); University of San Diego School of Law Faculty Workshop (expected Sep. 2019); University of Utah, SJ Quinney College of Law Faculty Scholarship Lunch (expected Sep. 2019); UC Irvine Law School, 2nd Trans-Pacific Business Law Dialogue (Aug. 2019); 2019 SEALS Annual Conference (Boca Raton, Florida, Jul. 2019); 2019 Junior Tax Scholars’ Workshop (Richmond Law School, Jun. 2019); Annual Meeting of the Law and Society Association (Washington, D.C., Jun. 2019). Presentation, Other, 11/2019.
• "Insulation by Separation: When Dual-Class Stock Met Corporate Spin-offs": 22nd Annual Critical Tax Conference (Pepperdine Law School, Apr. 2019); 2018 Rocky Mountain Junior Scholars Forum (University of Utah S.J. Quinney College of Law, Salt Lake City, Oct. 2018); Annual Meeting of the Law and Society Association (Toronto, Jun. 2018, presented by Geeyoung Min); National Business Law Scholars Conference (University of Utah S.J. Quinney College of Law, Jun. 2017, presented with Geeyoung Min). Presentation, Presented, 04/2019.
• "Engineering Pass-throughs in International Tax: The Case of Private Equity Funds": University of Utah, SJ Quinney College of Law Faculty Scholarship Lunch (Oct. 2018); 2018 Junior Tax Scholars’ Workshop, University of Colorado Law School (Boulder, Jun. 2018); Annual Meeting of the Law and Society Association, Toronto. Presentation, Presented, 10/2018.
• "Three Studies in International Taxation – Focusing on Private Equity Funds and Transparency", J.S.D. Dissertation Oral Defense, New York University School of Law, New York, NY. Presentation, Presented, 08/2018.
• "Pass-through in International Tax: The Case for Private Equity Funds", Annual Meeting of the Law and Society Association, Toronto. Presentation, Presented, 06/2018.
• "Altering Voting Rights Without Shareholder Approval: Dual-Class Stock in Tax-Free Corporate Spin-Offs" (with Geeyoung Min), Annual Meeting of the Law and Society Association, Toronto. Presentation, Presented, 06/2018.
• "A Study of the Taxation of International Private Equity Funds", New York University, J.S.D. Dissertation Oral Defense, New York. Presentation, Presented, 05/2018.
• "Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications", Utah State Bar Tax Section, Salt Lake City. Presentation, Presented, 03/2018.
• "Interrupted Continuity: Corporate Spin-off and Governance Disparity," with Geeyoung Min, National Business Law Scholars Conference (Salt Lake City). Presentation, Presented, 06/2017.
• "Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications," National Business Law Scholars Conference, Salt Lake City. Presentation, Presented, 06/2017.
• "Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications," Annual Meeting of the Law and Society Association, New Orleans . Presentation, Presented, 06/2016.
• "Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications," New York University J.S.D. Forum. Commentator: Professor Susan Morse (Univ. of Texas School of Law). Presentation, Presented, 01/2016.
• "Considering “Citizenship Taxation”: In Defense of FATCA," Student Panel, Taxation and Citizenship Conference, University of Michigan School of Law, Ann Arbor. Panel, Presented, 10/2015.
• "A Study of the Taxation of International Private Equity Funds," Poster Programme, 69th Congress of the International Fiscal Association, Basel, Switzerland. Poster, Presented, 08/2015.
• "Finding and Implementing a Better Rule for Taxing International PEFs," New York University J.S.D. Forum. Commentator: Professor Daniel Shaviro (New York University School of Law). Presentation, Presented, 12/2014.
• "A Study of the Taxation of International Private Equity Funds," Oxford University Centre for Business Taxation Fourth Annual Doctoral Meeting, Saïd Business School, University of Oxford. Commentator: Professor Glen Loutzenhiser (University of Oxford). Presentation, Presented, 09/2014.
• "Reforming the International Taxation of Cross-border Investments by Multinational Investment Entities," New York University J.S.D. Forum. Commentator: Professor Reuven Avi-Yonah (University of Michigan School of Law). Presentation, Presented, 03/2014.

Languages

• Korean, fluent.