Dissertation Title: A Study of the Taxation of International Private Equity Funds
Doctoral Committee: Professor Mitchell Kane (supervisor), Professor Daniel Shaviro, Professor Susan Morse (The University of Texas School of Law)
Young Ran (Christine) is a J.S.D. candidate from Korea. She received her Bachelor of Law degree summa cum laude from Seoul National University College of Law in South Korea (2002), where she graduated first in her class and received the President of Seoul National University Award. She earned her LL.M. from Harvard Law School (2012), where she was awarded the Landon H. Gammon Fellowship for academic excellence.
Young Ran is a member of the Korean Bar and the New York Bar. She has worked at Yulchon in Korea (2007-2011), Caplin & Drysdale in Washington, D.C. (2012-2013, 2014), and Sullivan & Cromwell in New York (2015). She was selected as an Up and Coming Capital Markets Lawyer by Chambers Global (2008) and by Chambers Asia (2010), and won several notable tax cases at the Supreme Court of Korea.
Young Ran’s area of interest is international tax policy and taxation on complicated investment structures. Young Ran’s J.S.D. project is built upon an insight that although cross-border investments by private equity funds (PEFs) raise unique policy concerns, there has been relatively little study for PEFs. In her dissertation, she will analyze the current international tax regime with regard to the taxation of PEFs, and suggest a new approach for PEFs, which will defer to the OECD’s basic policy on the taxation of funds while creating an implementation strategy using the exchange of information among tax authorities.
Young Ran (Christine) Kim, Considering “Citizenship Taxation”: In Defense of FATCA, Fla. Tax. Rev. (forthcoming 2017) (peer-reviewed journal)
Scott D. Michel, Zhanna Ziering & Young Ran Kim, U. S. Offshore Account Enforcement Issues, 16 J. Tax Practice & Procedure 65 (Aug./Sep. 2014).
Young Ran Kim, A Study of Derivatives Converting Character of Income and its Income Tax Recharacterization in Korea (LL.M. Long Paper) (2012).
Soo-Jeong Ahn, S.W. Song, Young Ran Kim & J.E. Chung, Taxation of Indirect Equity Transfers – South Korea, 17 Asia-Pacific Tax Bulletin 140 (Mar./Apr. 2011).
D.S. Kim, M.J. Lee & Young Ran Kim, 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 (May 2009) (S. Kor.).
Selected Scholarly Presentations
Carried Interest and Beyond: The Nature of Private Equity Investment and Its International Tax Implications
- New York University J.S.D. Forum (Jan. 2016). Commentator: Professor Susan Morse (The University of Texas School of Law)
- Annual Meeting of the Law and Society Association (New Orleans, Jun. 2016)
Considering “Citizenship Taxation”: In Defense of FATCA, Student Panel, Taxation and Citizenship Conference, University of Michigan School of Law (Ann Arbor, Oct. 2015)
A Study of the Taxation of International Private Equity Funds,
- 69th Congress of the International Fiscal Association, Poster Programme (Basel, Switzerland, Aug./Sep. 2015)
- Oxford University Centre for Business Taxation Fourth Annual Doctoral Meeting, Saïd Business School, University of Oxford (Oxford, Sep., 2014). Commentator: Professor Glen Loutzenhiser (University of Oxford)
Finding and Implementing a Better Rule for Taxing International PEFs, New York University J.S.D. Forum (Dec., 2014). Commentator: Professor Daniel Shaviro (New York University School of Law)
Reforming the International Taxation of Cross-border Investments by Multinational Investment Entities, New York University J.S.D. Forum (Mar., 2014). Commentator: Professor Reuven Avi-Yonah (University of Michigan School of Law)