SHU-YI OEI Tulane Law School Weinmann Hall, 6329 Freret Street, New Orleans, LA (617)

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PROFESSIONAL EXPERIENCE SHU-YI OEI Tulane Law School Weinmann Hall, 6329 Freret Street, New Orleans, LA 70118 soei@tulane.edu (617) 470-9872 Tulane Law School, New Orleans, LA, July 2009 present Hoffman F. Fuller Associate Professor of Tax Law (with tenure) (2014-present) Core Faculty, Tulane Murphy Institute (2014-present) Associate Professor (2009-2014) Courses: Federal Income Tax; Corporate Tax; International Tax; Tax Policy Seminar; Regulation & Coordination Workshop Awards: Felix Frankfurter Distinguished Teaching Award (2014) Service: Intellectual Life Committee (2014-15 (co-chair), 2013-14, 2012-13 (chair), 2011-2012); Hiring Committee (2013-14, 2010-2011); Library Committee (2009 2010); Co-Organizer, Tulane Tax Roundtable (2011-present); Co- Convenor, Regulation and Coordination Workshop (2015-present); Organizing Committee, Junior Tax Roundtable (2013-2014); Co- Organizer, Louisiana Junior Faculty Forum (2012 2014); Ad Hoc Committee on VAP appointments (Spring 2014, 2012 & 2011); Faculty Advisor to Tulane Law VITA program and Lambda Law Alliance University of California, Hastings College of the Law, San Francisco, CA, Fall 2014 Visiting Professor National University of Singapore Faculty of Law, Singapore, June July 2013 Visiting Scholar Harvard Law School, Cambridge, MA, July 2008 July 2009 Post-Graduate Research Fellow Bingham McCutchen LLP, Boston, MA, September 2003 May 2009 Tax Associate Advised clients on a wide variety of federal, state, and international tax matters. Structured sophisticated transactions involving issues of partnership, corporate, and cross-border taxation. Transactional experience included tax aspects of mergers and acquisitions, partnership agreements, and other contracts; drafting of opinion letters; and preparation of regulatory filings. Litigation experience included representing clients in tax controversies with the Internal Revenue Service and Massachusetts Department of Revenue. Bingham McCutchen LLP, Boston MA, Summer 2002 Summer Associate Shu-Yi Oei 6/15/15 1 of 8

EDUCATION Harvard Law School, Cambridge, MA J.D., June 2003 Women s Law Journal Selected to Harvard Legal Aid Bureau Harvard Divinity School, Cambridge, MA Master of Theological Studies, June 2003 Concentration in Christianity & Culture Brown University, Providence, RI A.B., May 1999, magna cum laude, Phi Beta Kappa Majors in Economics and Religious Studies, with honors in Religious Studies Anne Crosby Emery Scholar (awarded for graduate study) MAJOR PUBLICATIONS & WORKS-IN-PROGRESS Bank and Tax Evasion: A Framework for Regulation and Prosecution (in progress) The Tax Lives of Sharing Economy Workers: Evidence from Internet Discussion Forums (with Diane Ring) (in progress) Can Sharing be Taxed? 93 WASH. U. L. REV. (forthcoming 2016) (with Diane Ring) Human Equity? Regulating the New Income Share Agreements, 68 VAND. L. REV. 681 (2015) (with Diane Ring) The New Human Equity Transactions, 5 CAL. L. REV. CIRCUIT 266 (2014) (with Diane Ring) Taxing Bankrupts, 55 B.C. L. REV. 375 (2014) The Uneasy Case against Tax Lien Subordination, 11 PITT. TAX REV. 241 (2014) (symposium) Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, 46 UC DAVIS L. REV. 421 (2012) Getting More by Asking Less: Justifying and Reforming Tax Law s Offer in Compromise Procedure, 160 U. PA. L. REV. 1071 (2012) Beyond Economic Substance: Interrogating the Full Impacts of Third-Party Relationships in Tax Shelter Cases, 13 U. PA. J. BUS. L. 383 (2011) Context Matters: The Recharacterization of Leases in Bankruptcy and Tax Law, 82 AM. BANKR. L.J. 635 (2009) (peer-reviewed journal) A Structural Critique of Trader Taxation, 8 FLA. TAX REV. 1013 (2008) (peer-reviewed journal) Shu-Yi Oei 6/15/15 2 of 8

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 J. 49 (2004) SHORTER WORKS The Aftermath Of A Leak: What's Next in the HSBC Suisse Tax Evasion Saga?, JURIST - Academic Commentary, May 8, 2015, http://jurist.org/forum/2015/05/shu-yi-oei-taxevasion.php Responsive Regulation and Large Business Tax Compliance (review of Leigh Osofsky, Some Realism About Responsive Tax Administration, 66 TAX L. REV. 121 (2012) (June 1, 2012)), http://tax.jotwell.com/responsive-regulation-and-large-business-tax-compliance/ PRESENTATIONS & CONFERENCES Panelist & Co-organizer, AALS Annual Meeting Cross-Cutting Program, Peer-to-Peer Consumption: Emerging Legal Issues in the New Sharing Economy (New York, NY, expected January 2016) Presenter, The Tax Lives of Sharing Economy Workers: Evidence from Internet Discussion Forums, Brooklyn Law School Faculty Workshop (Brooklyn, NY, date TBD) Presenter, The Tax Lives of Sharing Economy Workers: Evidence from Internet Discussion Forums, University of Virginia Invitational Tax Conference, University of Virginia School of Law (Charlottesville, VA, expected Nov. 6-7, 2015) Presenter, Can Sharing Be Taxed?, Southeastern Association of Law Schools Annual Meeting (Boca Raton, FL, expected August 2015) Presenter, Bank and Tax Evasion: A Framework for Regulation and Prosecution, Association for Mid-Career Tax Law Professors Conference, Ohio State Moritz College of Law (Columbus, Ohio, expected June 4-5, 2015) Presenter, Can Sharing Be Taxed?, Law & Society Association Annual Meeting (Seattle, WA, expected May 28-31, 2015) Presenter, Can Sharing Be Taxed?, Sharing Economy, Sharing City: Urban Law and the New Economy Conference, Fordham Law School (New York, NY, April 24, 2015) Presenter, Can Sharing Be Taxed?, Critical Tax Conference, Northwestern Law School (Chicago, IL, April 3-4, 2015) Presenter, Can Sharing Be Taxed?, NYU Tax Policy Colloquium, NYU School of Law (New York, NY, March 31, 2015) Presenter, Can Sharing Be Taxed?, Pepperdine Tax Policy Workshop, Pepperdine School of Law (Malibu, CA, March 2, 2015) Shu-Yi Oei 6/15/15 3 of 8

Panelist & Co-Organizer, AALS Annual Meeting Bridge/Hot Topic Program Panel, Recent Developments in Human Capital Investing (Washington, DC, January 3, 2015) One of six Hot Topic/Bridge panel proposals selected by AALS Presenter, What is Fair Tax Administration?, National Tax Association 107th Annual Conference on Taxation (Santa Fe, NM, November 13-15, 2014) Presenter, Human Equity? Regulating the New Income Share Agreements, University of Washington Graduate Tax Program Second Annual Tax Symposium on the Future of the Tax Law (Seattle, WA, October 3, 2014) Presenter, Human Equity? Regulating the New Income Share Agreements, Loyola L.A. Tax Policy Colloquium (Los Angeles, California, September 22, 2014) Presenter, What is Fair Tax Administration?, Southeastern Association of Law Schools Annual Meeting (Amelia Island, FL, August 2014) Presenter, Human Equity? Regulating the New Income Share Agreements, Tulane Faculty Summer Brownbag Workshop Series (New Orleans, LA, July 16, 2014) Presenter, The New Human Equity Transactions, Critical Race Theory and Empirical Methods Public Symposium and Fifth Working Group Meeting, University of Denver, Strum College of Law (Denver, CO, June 18 and 19, 2014) Presenter, Drafting Tax Legislation, Tulane Public Law Center International Legislative Drafting Institute (New Orleans, LA, June 13, 2014) Presenter, Human Equity and Contemporary Ownership: Conceptualizing and Taxing the New Human Equity Transactions, Law & Society Association Annual Meeting (Minneapolis, MN, May 29, 2014) Presenter, The New Human Equity Transactions, Critical Tax Conference, University of Baltimore School of Law (Baltimore, MD, April 4-5, 2014) Presenter, Taxing Bankrupts, National Tax Association 106th Annual Conference on Taxation (Tampa Bay, FL November 21-23, 2013) Presenter, The New Human Equity Transactions, Tulane Law School Faculty Workshop Series (New Orleans, LA, November 18, 2013) Presenter, Taxing Bankrupts, Southeastern Law Schools Junior-Senior Conference, Emory Law School (Atlanta, GA, November 15-16, 2013) Presenter, Taxing Bankrupts, Seattle University School of Law Faculty Workshop (Seattle, WA, October 7, 2013) Presenter, The Case Against Tax Lien Subordination, Symposium on Duties to the Tax System, University of Washington School of Law (Seattle, WA, October 4, 2013) Shu-Yi Oei 6/15/15 4 of 8

Presenter, Taxing Bankrupts, UC Hastings College of Law Faculty Colloquium (San Francisco, CA, October 1, 2013) Presenter, Taxes and Student Loans, American Bar Association Section on Taxation Meeting (San Francisco, CA, September 20-21, 2013) Presenter, Taxing Bankrupts, Southeastern Association of Law Schools Annual Meeting (Palm Beach, FL, August 2013) Presenter, Taxing Bankrupts, Law & Society Association Annual Meeting (Boston, MA, May 31, 2013) Presenter, Federal User Fees in Agency, Political, and Business Context: The Case of Commercial Aviation, Junior Tax Scholars Workshop, University of Miami School of Law (Miami, FL, May 22-23, 2013) Presenter, Taxing Bankrupts, Washburn Tax Colloquium, Washburn University School of Law (Topeka, KS, April 26, 2013) Presenter, Taxing Bankrupts, Pittsburgh Tax Workshop, University of Pittsburgh School of Law (Pittsburgh, PA, March 20, 2013) Presenter, Taxing Bankrupts, Tulane Tax Roundtable, Tulane Law School (New Orleans, LA, February 22, 2013) Panelist, Socio-Economic Perspectives on Tax Policy, AALS Section on Socio-Economics Annual Meeting (New Orleans, LA, January 4, 2013) Presenter, Taxing Bankrupts, ClassCrits V: From Madison to Zuccotti Park: Confronting Class and Reclaiming the American Dream, University of Wisconsin Law School (Madison, WI, November 16-17, 2012) Commentator on Leonard E. Burman (Syracuse University), Pathways to Tax Reform Revisited, Tulane Murphy Institute Fiscal Trilemma Conference (New Orleans, LA, October 26, 2012) Presenter, Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, The Carter Commission 50 Years Later: A Time for Reflection and Reform, Dalhousie University Schulich School of Law (Halifax, Nova Scotia, September 28-29, 2012) Presenter, Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, 2012 International Conference on Law & Society (Honolulu, HI, June 5-8, 2012) Presenter, Should Tax Debts be Paid before Private Debts? A Tax Policy Defense of Bankruptcy Priority, Junior Tax Scholars Workshop, UC Hastings College of the Law (San Francisco, CA, May 30-31, 2012) Shu-Yi Oei 6/15/15 5 of 8

Organizer, Presenter & Discussant, Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, Tulane Tax Roundtable, Tulane Law School (New Orleans, LA, April 13-14, 2012) Presenter, Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, Critical Tax Conference, Seton Hall Law School (Newark, NJ, March 30-31, 2012) Presenter, Who Wins When Uncle Sam Loses? Social Insurance and the Forgiveness of Tax Debts, Northwestern University School of Law Colloquium on Advanced Topics in Taxation (Chicago, IL, March 8, 2012) Commentator on Mark Weidemaier (UNC), Changing Law to Change Contracts: The Joint Evolution of Sovereign Immunity and Sovereign Bonds, Tulane Law School Intellectual Life Speaker Series (New Orleans, LA, November 2011) Presenter, Owing Uncle Sam: Warring Visions of Government in the Law and Practice of Tax Collections and IRS Forbearance, ClassCrits IV: Criminalizing Economic Inequality, American University Washington College of Law (Washington, DC, September 2011) Presenter, Getting More by Asking Less: The Role of Stakeholder Dynamics in Reforming Tax Law s Offer in Compromise Procedure, Southeastern Association of Law Schools Annual Meeting (Hilton Head, SC, July 2011) Presenter, The Function of the Fiction: Envisioning a Debt-Equity Distinction for Natural Persons, Junior Tax Scholars Workshop, UC Irvine School of Law (Irvine, CA, June 2011) Presenter, Drafting Tax Legislation, Tulane Public Law Center International Legislative Drafting Institute (New Orleans, LA, June 2011) Presenter, Getting More by Asking Less: The Role of Stakeholder Dynamics in Reforming Tax Law s Offer in Compromise Procedure, Tulane Law School Faculty Summer Brown Bag Series (New Orleans, LA, June, 2011) Presenter, Getting More by Asking Less: The Role of Stakeholder Dynamics in Reforming Tax Law s Offer in Compromise Procedure, Law & Society Association Annual Meeting (San Francisco, CA, June 2011) Presenter, Getting More by Asking Less: The Role of Stakeholder Dynamics in Reforming Tax Law s Offer in Compromise Procedure, Critical Tax Conference, Santa Clara Law School (Santa Clara, CA, April 2011) Organizer, Presenter & Discussant, Reforming Tax Law s Offer in Compromise Procedure, Tulane Tax Policy Roundtable, Tulane Law School (New Orleans, LA, March 2011) Presenter, Reforming Tax Law s Offer in Compromise Procedure, Louisiana Junior Faculty Workshop Series, Louisiana State University Hebert Law Center (Baton Rouge, LA, February 2011) Shu-Yi Oei 6/15/15 6 of 8

Presenter, Reforming Tax Law s Offer in Compromise Procedure, Indiana University Maurer School of Law Tax Policy Colloquium Series (Bloomington, IN, February 2011) Workshop Presenter, In Defense of Mercy and Sympathy in the Tax Law, Tulane Law School Junior Faculty Workshop Series (New Orleans, LA, September 2010) Presenter, In Defense of Mercy and Sympathy in the Tax Law, Third National People of Color Legal Scholarship Conference Work-in-Progress Sessions, Seton Hall Law School (Newark, NJ, September 2010) Presenter, Relationships and Respect: Interrogating the Impacts of Third-Party Relationships in Tax Shelter Cases, Third National People of Color Legal Scholarship Conference, Seton Hall Law School (Newark, NJ, September 2010) Presenter, Relationships and Respect: Interrogating Taxpayer Relationships in Shelter Cases, Tulane Law School Faculty Summer Brown Bag Series (New Orleans, LA, July, 2010) Presenter, Drafting Tax Legislation, Tulane Public Law Center International Legislative Drafting Institute (New Orleans, LA, June 2010) Panelist, Biggest Triumphs and Mistakes: Junior Faculty Perspectives, AALS Workshop for New Law School Teachers (Washington, DC, June 2010) Presenter, The Law and Language of Relationships in Tax Shelter Adjudication, Junior Tax Scholars Workshop, Notre Dame Law School (South Bend, IN, June 2010) Presenter, The Law and Language of Relationships in Tax Shelter Adjudication, Law & Society Association Annual Meeting (Chicago, IL, May 2010) Selected Participant, Law & Society Association Early Career Workshop (Chicago, IL, May 2010) OTHER PROFESSIONAL ACTIVITIES Contributing Editor, Journal of Things We Like (Lots) Tax Section, www.jotwell.com AALS Tax Section, Executive Committee (2015-present) PROFESSIONAL LICENSE Admitted to practice in Massachusetts COMMUNITY AND VOLUNTEER ACTIVITIES Massachusetts Asians and Pacific Islanders for Health, Boston, MA, March 2008 August 2009 Board of Directors Member and Personnel Chair Board member of non-profit organization that advocates for Asian, South Asian, and Pacific Islander health improvements. Work on fundraising initiatives. Shu-Yi Oei 6/15/15 7 of 8

Harvard Hapkido Club, Cambridge, MA, October 1999 May 2009 Founding Member and Co-Instructor Practiced and taught martial arts two to three times a week on a volunteer basis. Achieved the rank of third degree black belt. LANGUAGES Mandarin Chinese Basic German Shu-Yi Oei 6/15/15 8 of 8