The International Fiscal Association (USA Branch) is pleased to announce the
IFA USA BRANCH
2008 WRITING COMPETITION
SUBMISSION DEADLINE: October 31, 2008

For more information send an email to Prof. Allison Christians, achristians@wisc.edu or Prof. Skip Patton, propfpat@bu.edu

The winning entrant will be presented with a cash prize at the IFA USA Branch Annual Meeting in February, 2009. Submissions may be on any topic relating to United States taxation of income from international activities, including taxation under U.S. tax treaties.

The IFA 2008 Writing Competition is open to all students pursuing a U.S. graduate degree with a tax focus during the 2007-2008 academic year.

IFA USA BRANCH
2008 Writing Competition Rules

1. Eligibility/topics. Papers must be written by full or part-time students pursuing a degree at the graduate level (J.D., L.L.M., S.J.D, M.S.T., MTA, Masters of Taxation, or similar program), on a topic involving the application of U.S. tax rules to international activities.
a. Papers must be no more than 40 typewritten pages in length (double-spaced in 12 pt. font), including footnotes and appendices (both of which may be single-spaced), and in proper citation form.
b. Papers written in connection with a school course or seminar offered during the 2007-08 academic year (including independent study and 2008 summer school courses) are eligible for the IFA Competition.
c. Papers based on research or other work done in connection with law firms or other employment are eligible for the IFA Competition, as are papers evolving from moot court or legal clinic involvement. Any such papers, however, must be in the form of a scholarly article. Client-specific work products (e.g., briefs, legal memoranda, opinion letters, etc.) will not be accepted.
d. Student papers submitted for publication in law reviews or other legal journals or periodicals are eligible for the IFA Competition, provided that the version submitted for the IFA Competition shall not reflect any changes made to the paper after submission of the manuscript to any publication.
e. Student papers submitted to other competitions are eligible for the IFA Competition.

2. Faculty sponsors. Each submitted paper must be sponsored by a professor at the student’s school or university.
a. Consistent with normal levels of professor supervision with respect to student papers prepared for graduate school courses, the faculty sponsor may
(i) assist the submitting student in selecting a topic,
(ii) discuss outlines or drafts of the paper with the student, and
(iii) offer suggestions with respect to organization and substantive content of the paper.
b. The faculty sponsor shall furnish to the Reviewing Committee, along with each submitted paper, a signed letter or other written communication confirming that he or she reviewed the final draft of the paper and consents to being named as faculty sponsor of the paper.
c. The same professor may serve as the faculty sponsor of no more than three papers submitted for this year’s Competition.

3. Per-school limits. No more than three papers may be submitted by students from the same school or university for this year’s Competition.

4. Cover page information. Each submitted paper shall include a cover page displaying:
(i) the title of the article;
(ii) the name, educational institution and class, address, phone number and email address of the submitting student; and
(iii) the name, address, phone number and e-mail address of the faculty sponsor.
The names of the student, faculty sponsor or their school should not otherwise appear in the paper.

5. Deadline for submission. All papers submitted for the Competition must be received by the Reviewing Committee by October 31, 2008.

6. Format of Submission. The original of each paper should be transmitted by email as a Microsoft Word or pdf attachment to:
Prof. Allison Christians of the University of Wisconsin Law School at achristians@wisc.edu, Prof. Brainard Patton of Boston University School of Law at profpat@bu.edu and Prof. William Streng of the University of Houston Law Center at WStreng@central.UH.edu.

7. Selection of winners. Winning papers will be selected by the IFA’s Reviewing Committee based on, among other factors,
(i) depth and creativity of legal analysis;
(ii) thoroughness of legal research;
(iii) organization and writing style;
(iv) difficulty of subject matter; and
(v) consideration of tax policy implications. The Reviewing Committee will use its best efforts to arrange for publication of the first-prize paper in a professional tax publication. Competition winners will be notified by December 31, 2008.

8. Prizes. A $2,000 cash prize will be awarded for the winning paper. The author of the winning submission will be invited to attend the Annual Meeting of the U.S. Branch in Washington, D.C., in February 2009, for presentation of the prize. Registration fees, domestic travel, and accommodations will be provided. The Reviewing Committee may, in its discretion, decide to split prizes or award additional prizes.

9. Inquiries. Any inquiries regarding the Competition should be directed to either Professor Patton or Professor Christians at the above email addresses or by telephone at 781-934-2354 or 608-890-0912, respectively.

Click here to download the 2008 IFA Writing Competition information document

The USA Branch of the International Fiscal Association is pleased to announce that Jason Sullivan, a 2008 graduate with an LL.M. in Taxation of the University of Florida Levin College of Law, has won the 2008 IFA USA Branch Writing Prize competition with his submission: “Hybrid Instruments in an International Tax Context”. This paper provides a thorough overview of the checkered history of section 385 and other U.S. rules for characterizing debt and equity, addresses the opportunities created for sophisticated taxpayers to create hybrid instruments and for exploiting the rules for substance over form, particularly with respect to claim foreign tax credits for U.S. tax purposes, and considers the impact of the Temporary Regulations issued in 2008 to address perceived foreign tax credit abuses from use of hybrid instruments.


The paper is going to be published in March as a Special Report in Tax Notes International. Jason slightly modified the paper for Tax Notes and one of the changes was the title. The title for Tax Notes International is: "Debt-Equity Hybrid Instruments in a Cross-Border Setting: A Focus on the U.S. Foreign Tax Credit."


Mr. Sullivan’s faculty sponsor was Prof. Lawrence Lokken of the University of Florida Levin College of Law. The prize was awarded to Mr. Sullivan at the 2009 Annual Meeting in Washington, DC on February 27th.


Mr. Sullivan is currently Senior Associate, Tax, International Corporate Services, with KPMG in Charlotte, NC.

The International Fiscal Association (USA Branch) is pleased to announce the winner of the IFA USA Branch 2007 Writing Competition is David Pozen, for his excellent paper,
"Tax Expenditures as Foreign Aid". Mr. Pozen is currently based in Washington, where he is a fellow (Yale Law School Heyman Federal Public Service Fellowship) for the 2007-2008 academic year serving on Senator Kennedy's Judiciary Committee staff as "Special Assistant to Senator Kennedy".


The IFA USA Branch Annual Writing Competition is open to all students pursuing a U.S. graduate degree with a tax focus during the current academic year. Submissions may be on any topic relating to United States taxation of income from international activities, including taxation under U.S. tax treaties.


The winning entrant is presented with a cash prize at the IFA USA Branch Annual Meeting.