Aaron Burton, FTL Denver Chapter Social Committee Chair, and Greg Janssen, both students of University of Denver’s Graduate Tax Program, placed third in the second round of the American Bar Association’s Tax Section’s Law Student Tax Challenge, a national competition held in Los Angeles, CA, on January 29, 2016.
The competition begins each year with a problem written by the Tax Section involving a theoretical client’s complex business transaction. The Tax Section invites law students from across the country to submit a 12-page partner’s memo and a 4 page letter to the client analyzing the transaction. Both the memo and the letter can be written by a team of two students.
This year the problem involved a proposed transaction in which a seven year tax dispute with a foreign government would be settled so that foreign tax credits could be assessed against a mid-tier foreign subsidiary and subsequently flowed through to a domestic corporate parent through a check-the-box election to treat the mid-tier foreign subsidiary as a disregarded entity.
The top four submissions are selected for the second round which involves an in-person meeting with several senior partners and the client. At the mock meeting participants are judged on how well they defend their analysis orally. The meeting takes place at the ABA Tax Section’s annual conference and judges include partners at major law and accounting firms, IRS officials, and tax court judges.
(In photo from left to right: Aaron Burton, Student of University of Denver’s Graduate Tax Program, John Wilson, Director of University of Denver’s Graduate Tax Program, and Greg Janssen, Student of University of Denver’s Graduate Tax Program.)