Shu-Yi Oei

Forthcoming

The Origination Clause and The President's Tariffs, 103 Washington University Law Review (forthcoming) (with others)
Global Tax Decluttering, 77 UC Law Journal (forthcoming) (with Diane M. Ring)

Works in Progress

Beyond the Nation State: Transnational Actors and Networks in Post-2008 Global Tax Reform (January 1, 2025)
Disentangling Power and Preferences in Tax Treaty Negotiations: Analyzing Tax Treaties between Developing and OECD Countries Using Multilevel Modeling (July 24, 2024)
Regulating in Pandemic: Evaluating Economic and Financial Policy Responses to the Coronavirus Crisis (March 17, 2020) (with others)
Is New Code Section 199A Really Going to Turn Us All Into Independent Contractors? (January 12, 2018) (with Diane M. Ring)

Books

Federal Income Taxation (Aspen Publishing, 6th ed. 2023) (with others)

Articles & Essays

The Conflictual Core of Global Tax Cooperation, 16 World Tax Journal 663-717 (2024) (with Diane M. Ring)
Fiscal Policies to Mitigate Climate Change in the United States: Competing Goals and Conflicting Priorities, in Fiscal Policies to Mitigate Climate Change 629-646 (Marilyne Sadowsky ed., 2023) (with Diane M. Ring)
World Tax Policy in the World Tax Polity? An Event History Analysis of OECD/G20 BEPS Inclusive Framework Membership, 47 Yale Journal of International Law 199-236 (2022)
"Slack" in the Data Age, 73 Alabama Law Review 47-106 (2021) (with Diane Ring)
United States, in Taxation and Value Creation 669-689 (Werner Haslehner & Marie Lamensch eds., 2021)
Tax Law’s Workplace Shift, 100 Boston University Law Review 651-721 (2020) (with Diane M. Ring)
The Importance of Qualitative Research Approaches to Gig Economy Taxation, in Beyond the Algorithm: Qualitative Insights for Gig Work Regulation 82-102 (Deepa das Acevedo ed., 2020) (with Diane M. Ring)
Constituencies and Control in Statutory Drafting: Interviews With Government Tax Counsels, 104 Iowa Law Review 1291-1360 (2019) (with Leigh Osofsky)
Legislation and Comment: The Making of the § 199A Regulations, 69 Emory Law Journal 209-271 (2019) (with Leigh Osofsky)
When Data Comes Home: Next Steps in International Taxation’s Information Revolution, 64 McGill Law Journal 707-762 (2019) (with Diane M. Ring)
Leak-Driven Law, 65 UCLA Law Review 532-618 (2018) (with Diane Ring)
Tax Issues in the Sharing Economy, in The Cambridge Handbook of the Law of the Sharing Economy 343-356 (Nestor M. Davidson, Michèle Finck & John J. Infranca eds., 2018) (with Diane M. Ring)
The Offshore Tax Enforcement Dragnet, 67 Emory Law Journal 655-733 (2018)
The Trouble With Gig Talk: Choice of Narrative and the Worker Classification Fights, 81 Law and Contemporary Problems 107-136 (2018)
The Tax Lives of Uber Drivers: Evidence From Internet Discussion Forums, 8 Columbia Journal of Tax Law 56-112 (2017) (with Diane M. Ring)
Can Sharing be Taxed?, 93 Washington University Law Review 989-1069 (2016) (with Diane M. Ring)
Supply, Demand, and the Taxation of Knowledge, 82 University of Chicago Law Review Dialogue 268-283 (2016)
Human Equity? Regulating the New Income Share Agreements, 68 Vanderbilt Law Review 681-760 (2015) (with Diane Ring)
Taxing Bankrupts, 55 Boston College Law Review 375-434 (2014)
The New “Human Equity” Transactions, 5 California Law Review Circuit 266-277 (2014) (with Diane M. Ring)
The Uneasy Case Against Tax Lien Subordination, 11 Pittsburgh Tax Review 241-280 (2014)
Getting More by Asking Less: Justifying and Reforming Tax Law’s Offer in Compromise Procedure, 160 University of Pennsylvania Law Review 1071-1137 (2012)
Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, 46 UC Davis Law Review 421-486 (2012)
Beyond Economic Substance: Interrogating the Full Impacts of Third-Party Relationships in Tax Shelter Cases, 13 University of Pennsylvania Journal of Business Law 383-443 (2011)
A Structural Critique of Trader Taxation, 8 Florida Tax Review 1113-1168 (2008)
Context Matters: The Recharacterization of Leases in Bankruptcy and Tax Law, 82 American Bankruptcy Law Journal 635-692 (2008)
Rethinking the Jurisdiction of Bankruptcy Courts over Post-Confirmation Federal Tax Liabilities: Towards a New Jurisprudence of 11 U.S.C. § 505, 19 Akron Tax Journal 49-97 (2004)

Newspaper Articles and Commentary

U.S. Tax Policy and Puerto Rico’s Fiscal History, JOTWELL (July 5, 2016) (reviewing Diane Lourdes Dick, U.S. Tax Imperialism in Puerto Rico, 65 American University Law Review 1-86 (2015))
Regulatory Gray Areas, Uncertainty, and “Human Equity”, JOTWELL (January 8, 2016) (reviewing Benjamin M. Leff & Heather Hughes, The Income-Based Repayment Swap: A New Method for Funding Law School Education (2015))
The Aftermath of a Leak: What’s Next in the HSBC Suisse Tax Evasion Saga?, JURIST (May 7, 2015)
Responsive Regulation and Large Business Tax Compliance, JOTWELL (June 1, 2012) (reviewing Leigh Osofsky, Getting Realistic About Responsive Tax Administration, 66 Tax Law Review 121-178 (2012))

Directory

Bibliography

Forthcoming

Works in Progress

Books

Articles & Essays

Newspaper Articles and Commentary