TaxProf Blog

Saturday:

• This Week’s Ten Most Popular TaxProf Blog Posts
• ABA Plan To Double Experiential Learning Accreditation Requirement Spurs Criticism About Accreditor Overreach
• Holden & Kisska-Schulze: The Taxable Future Of College Sports
• Kuehn & Joy: Measuring The Impacts Of Experiential Legal Education
• Today’s Law, Society, And Taxation Panel

Sunday:

• Reviews Of Ross Douthat’s Believe ‘A Mere Christianity For The 21st Century’
• The Empty Ecstasy Of Digital Crowds
• Pope Leo Teaches A Lesson From Jesus That JD Vance Should Listen To
• Today’s Law, Society, And Taxation Panels
• Velasco: Shortcomings Of Law School And Big Law
• The Top Five New Tax Papers

Memorial Day:

• Things Worth Remembering On Memorial Day: ‘Do Not Mourn Me Dead’
• Raskolnikov: Law For The Rich
• California Bar Notifies Another Tranche Of Test-Takers Who Were Told They Flunked But Actually Passed; Bar Petitions Supreme Court To Extend COVID-Era Provisional Licensure To Over 3,000 Victims Of Botched February Exam
• Curbing Multinational Digital Tax Avoidance With The General Anti-Avoidance Rule

https://taxprof.typepad.com/taxprof_blog/2025/05/taxprof-blog-weekend-roundup-3.html

Reuters, ABA Plan to Boost Law Students’ Hands-On Experience Spurs Criticism About Accreditor Overreach:

The American Bar Association’s proposal to double the number of hands-on learning credits that law students must complete to graduate has sparked criticism that the accrediting organization is going too far in controlling the curriculum for legal education.

Under the proposed change to the ABA’s law school accreditation standards, the number of credits for hands-on learning, known as experiential learning, which students must take would go to 12 from the current six. Students would need to earn at least three of those credits in a clinic or a field placement. And none of the experiential credits — which include clinics, externships, or simulation courses that aim to recreate real legal work — could be taken in a law student’s first year.

The ABA, which says that the change is necessary to produce practice-ready graduates, adopted the six-credit experiential learning requirement in 2014, but surveys of recent graduates and legal employers continue to find that young lawyers are unprepared, according to the proposal.

The ABA’s Council of the Section of Legal Education and Admission to the Bar is gathering public comments on the proposal through June 30 with final adoption possible in August. If approved, the changes would go into effect in 2030.

Supporters [Robert Kuhn (Washington University)] and opponents [Daniel Rodriguez (Northwestern) and David Yellen (Miami)] are making their cases now, before the comment period closes.

Prior TaxProf Blog coverage:

• ABA, Legal Ed Council Proposes To Double Experiential Learning Accreditation Requirement To 12 Credits
• Barry Currier (Former Managing Director, ABA Section of Legal Education and Admissions to the Bar):
  • Attacks on Law Schools and the Regulation of Legal Education, Part 1
  • Attacks on Law Schools and the Regulation of Legal Education, Part 2
• Brian Leiter (Chicago), Law Schools Should Oppose an ABA Proposal to Double the Experiential Learning Credits From 6 to 12
• Derek Muller (Notre Dame), Inside the ABA’s Relentless Quest to Make Law School Accreditation More Tedious and More Expensive
• Daniel Rodriguez (Northwestern), ABA Accreditation Once More: Are They Making Me Eat My Words?
• David Yellen (Miami), The ABA Standards And Regulatory Modesty

Editor’s Note: If you would like to receive a daily email with links to legal education posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/aba-plan-to-double-experiential-learning-accreditation-requirement-spurs-criticism.html

USA Today, DEI dropped: Medical schools won’t be graded on diversity amid federal, state crackdown:

Citing state crackdowns on diversity, equity and inclusion, the organization that accredits medical schools has dropped diversity as a measure of the quality of medical education.

The Liaison Committee on Medical Education on May 19 voted to eliminate diversity programs and partnerships as criteria when it grades the performance of medical schools that confer “MD” degrees to students.

The liaison committee said it acted because new and proposed state laws targeting diversity, equity and inclusion conflict with the accrediting body’s standards. Eliminating diversity standards would create “a single set of accreditation expectations with which all schools, regardless of their location and current legislative environment, must comply,” the liaison committee said in a statement.

Inside Higher Ed, Medical School Accreditor Eliminates Diversity Standard:

The body that accredits medical schools leading to MD degrees has dropped diversity as a standard, USA Today reported.

The Liaison Committee on Medical Education, which is sponsored by the Association of American Medical Colleges and the American Medical Association, voted to stop evaluating diversity programs as a measure of a medical school’s quality after “thoughtful and careful consideration and discussion,” according to a committee spokesperson.

In the 2023 edition of the published accreditation manual, which went into effect July 1, 2024, the academic and learning standards include a section on diversity programs and partnerships, which says medical schools should have policies and practices in place “to achieve mission-appropriate diversity outcomes” among students, faculty and administrators.

• Chronicle of Higher Education, The Weaponization of Accreditation
• Chronicle of Higher Education, What Trump’s Accreditation Moves Get Right

Prior TaxProf Blog coverage:

• Under Trump Pressure, ABA Is Poised To Suspend Law School DEI Accreditation Standard Through August 2026 (May 7, 2025)
• ABA Legal Ed Council Votes Unanimously To Suspend Law School Diversity Accreditation Standard Until August 31, 2026 Due To Trump’s DEI Crackdown (May 10, 2025)

https://taxprof.typepad.com/taxprof_blog/2025/05/medical-school-accreditor-eliminates-diversity-standard-will-the-aba-be-next.html

Following up on yesterday’s post, What Could A Hostile Federal Government Do To Law Schools?: Daniel B. Rodriguez (Northwestern; Google Scholar), The Wars on Universities & Law Schools:

An intriguing post here on potential threats by Trump administration actions against law schools. This of course lies currently in the shadow of the vigorous battles being fought against Harvard especially, Columbia, and other universities presumably to be named as events unfold. There is much to say about the contours of such battles, but this small post focuses on law schools in particular, and adds one addendum to the post linked above and a broader point which is merely food for thought. …

As to what risks law schools face by federal actions that take away benefits (entitled or merely a privilege, as ultimately courts will need to sort out), let me add one important additional risk and that is employment by federal and even state governments. Many law graduates seek employment by federal agencies and key cabinet departments (e.g., the Dep’t of Justice); some as well look for opportunities in the U.S. military. And a critical mass aspire to clerkships with one or another federal judge. All of these opportunities, even judicial clerkships are in great peril if the presidential administration makes it clear that graduates from certain schools are not welcome. Acknowledging that there may well be some legal problems with fed decisions that are inexplicable except as retaliation for viewpoint, as has been pointed out by leading scholars, we can imagine a persistent reticence at the very least by federal officials to make employment decisions favorable to graduates of X or Y school during the pendency of conflicts between the administration and their universities. To put it in blunter terms, disfavored law schools will face a steep climb to compete on acceptable terms with law schools not in harm’s way, perhaps in the long term and almost certainly in the short term. …

Events are rapidly unfolding and we should be cautious about making clear predictions or state profound platitudes about the state of affairs. But with that caveat in mind, let me just say (again with reluctance, given how deeply I believe that President Trump’s present war against Harvard is so utterly misguided and even immoral) that law schools should work diligently with their university leadership to stave out attacks and broker some compromise, insofar as this work is consistent with the fundamental mission and objectives of these institutions. The battles not fought will be the ones that may well sort out law schools that will continue to thrive from those who become long-term casualties in a war that is waged between parties with unequal resources.

To be sure, I have elided the harder questions of how to think constructively about the best uses of political and institutional capital to find some common ground. These are difficult matters, especially in a world in which some of the attacks rest on such profoundly dubious and egregious assumptions and beliefs about higher education’s purpose and centrality to our civil society. But distinguished academics who have been speaking about the imperative of inter-institutional reform, including efforts at enhancing ideological diversity, transparency, inclusiveness upon multiple dimensions, and combating insularity, should be heeded, especially by those in positions of leadership and institutional power. Alongside the admirable efforts of Harvard and other vulnerable institutions to fight for what is right and to speak truth to power, we should also be working hard in our law schools and universities to implement concrete steps to address real and long-festering inter-institutional problems. We should do it because it makes good political sense; and we should do it because, as stewards of long-term progress in the development and transmission of knowledge to present and future generations, it is very much the right thing to do.

Editor’s Note: If you would like to receive a daily email with links to legal education posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/rodriguez-the-trump-war-on-universities-and-law-schools.html

Legal Education:

1. Paul Caron (Dean, Pepperdine), Projected 2026-27 U.S. News Law School Rankings: Overall
2. New York Times, 89-Year Old Retired Florida Professor Left Bulk Of Her $2.8 Million Estate To 31 Former Students
3. Adam Bonica (Stanford), Adam Chilton (Chicago), Kyle Rozema (Northwestern) & Maya Sen (Harvard), Law Professors Have Become More Liberal, But They Also Have Become More Conservative Than Their Students
4. ABA Press Release, ABA Legal Ed Council Votes Unanimously To Suspend Law School Diversity Accreditation Standard Until August 31, 2026 Due To Trump’s DEI Crackdown
5. Manhattan Institute, It’s Time For Professors to Teach More
6. The Intercept, NYU About-Face: Law Students Can Take Exams Without Renouncing Protests
7. Brian Leiter (Chicago) & Daniel Rodriguez (Northwestern), Opposition Grows To ABA’s Proposal To Double The Experiential Learning Accreditation Requirement
8. ABA Journal, ABA Legal Ed Council Proposes To Double Experiential Learning Accreditation Requirement To 12 Credits
9. Indiana-McKinney Law, Death Of James P. White, ABA Consultant On Legal Education (1974-2000)
10. Jonathan Turley (George Washington), Oregon Law Professor Accuses Oregon Law Review of Anti-Israeli Discrimination

Editor’s Note: If you would like to receive a daily email with links to legal education posts on TaxProf Blog, email me here.

Tax:

1. Wall Street Journal, Will Tax Complexity Force Pope Leo To Renounce His U.S. Citizenship?
2. Call For Tax Papers, Washington University Law Review Symposium On Taxing, Spending, And The Constitution
3. Trevor Fry (J.D. 2025, Boston College), For Everything Else, There’s Taxes: Why Credit Card Rewards Should Stop Being Priceless
4. Rebecca Kysar (Fordham), The Stakes Of The Global Tax Deal For International Economic Governance
5. Brian Leiter (Chicago), Lucy Msall Joins Chicago Tax Faculty
6. ABA Tax Section, May Meeting Kicks Off In Washington, D.C.
7. Orly Mazur (SMU) & Adam Thimmesch (Nebraska), Cooperative Federalism And The Digital Tax Impasse
8. Bridget Crawford (Pace), Confronting Inequality: Three Eras Of Gender And Tax Scholarship
9. David Elkins (Netanya), Review Of The Normative Shift In Corporate Tax Policy After GloBE By Tarcisio Diniz Magalhães (Antwerp) & Allison Christians (McGill)
10. SSRN, The Top Five New Tax Papers

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

Faith:

1. David Brooks, How To Survive The Trump Years With Your Spirit Intact
2. Harvard Law, ‘A Citizen of Heaven And Harvard’: Honoring The Life And Ongoing Impact Of Bill Stuntz
3. New York Times Op-Ed (Ross Douthat), What The World Needs From Pope Leo
4. Dispatch Faith (Alastair Roberts (Theopolis Institute)), Is Empathy A Sin?
5. Holy See Press Office, Pope Leo’s First Homily Richard Murphy (Funding the Future), Christianity And ChatGPT

Editor’s Note: If you would like to receive a weekly email each Sunday with links to faith posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/this-weeks-ten-most-popular-taxprof-blog-posts-2.html

Tax presentations at the Biennial Conference on International Economic Law hosted by the University of Michigan Law School and the American Society of International Law (program):

Assaf Harpaz (Georgia; Google Scholar), Global Tax Wars in the Digital Era, 75 Am. U. L. Rev. ___ (2025) (reviewed by Mirit Eyal (Alabama; Google Scholar) here):

The digital economy fundamentally disrupts traditional international tax principles that rely on physical presence. When a business earns income abroad, the country of residence (where the taxpayer resides) and the country of source (where income is generated) both have legitimate, competing claims to tax that income. The international tax system favors residence-based taxation. The source country has the right to tax business profits only if the enterprise carries on a permanent establishment within its borders, which typically requires a physical presence. The permanent establishment standard becomes flawed in a digital economy where profit shifting practices are abundant and businesses no longer need a physical presence in the location of their online consumer markets.

An upcoming United Nations (UN) Framework Convention on International Tax Cooperation recognizes these challenges and is overwhelmingly supported by Global South economies. However, the Global North has historically dominated the international tax regime through the Organization for Economic Cooperation and Development (OECD), informally known as the “World Tax Organization.” A UN framework convention creates potential conflict in international tax policymaking and would need to bridge the underlying North-South divide.

This article explores the “tax wars” surrounding the leadership for global tax governance, contrasting the taxing powers and interests of the OECD-led Global North with those of the UN-backed Global South. It argues for a shift toward source-based taxation by revisiting the permanent establishment standard. To achieve this, the article introduces a significant economic presence doctrine that would expand the permanent establishment criteria to include online businesses. This proposal addresses longstanding inequities and is increasingly warranted in a digital economy that does not depend on physical presence.

Panel on International Tax Cooperation:

• Steven Dean (Boston University; Google Scholar) (chair)
• Jennifer Farrell (Western Ontario)
• Young Ran (Christine) Kim (Cardozo; Google Scholar)
• Badriyya Yusuf (Queen’s University)

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/tax-prof-presentations-at-the-biennial-conference-on-international-economic-law-today-at-michigan.html

New York Times, The Professors Are Using ChatGPT, and Some Students Aren’t Happy About It:

In February, Ella Stapleton, then a senior at Northeastern University, was reviewing lecture notes from her organizational behavior class when she noticed something odd. Was that a query to ChatGPT from her professor?

Halfway through the document, which her business professor had made for a lesson on models of leadership, was an instruction to ChatGPT to “expand on all areas. Be more detailed and specific.” It was followed by a list of positive and negative leadership traits, each with a prosaic definition and a bullet-pointed example. …

Ms. Stapleton decided to do some digging. She reviewed her professor’s slide presentations and discovered other telltale signs of A.I.: distorted text, photos of office workers with extraneous body parts and egregious misspellings.

She was not happy. Given the school’s cost and reputation, she expected a top-tier education. This course was required for her business minor; its syllabus forbade “academically dishonest activities,” including the unauthorized use of artificial intelligence or chatbots.

“He’s telling us not to use it, and then he’s using it himself,” she said.

Ms. Stapleton filed a formal complaint with Northeastern’s business school, citing the undisclosed use of A.I. as well as other issues she had with his teaching style, and requested reimbursement of tuition for that class. As a quarter of the total bill for the semester, that would be more than $8,000.

When ChatGPT was released at the end of 2022, it caused a panic at all levels of education because it made cheating incredibly easy. Students who were asked to write a history paper or literary analysis could have the tool do it in mere seconds. Some schools banned it while others deployed A.I. detection services, despite concerns about their accuracy.

But, oh, how the tables have turned. Now students are complaining on sites like Rate My Professors about their instructors’ overreliance on A.I. and scrutinizing course materials for words ChatGPT tends to overuse, like “crucial” and “delve.” In addition to calling out hypocrisy, they make a financial argument: They are paying, often quite a lot, to be taught by humans, not an algorithm that they, too, could consult for free.

For their part, professors said they used A.I. chatbots as a tool to provide a better education. Instructors interviewed by The New York Times said chatbots saved time, helped them with overwhelming workloads and served as automated teaching assistants.

Their numbers are growing. In a national survey of more than 1,800 higher-education instructors last year, 18 percent described themselves as frequent users of generative A.I. tools; in a repeat survey this year, that percentage nearly doubled, according to Tyton Partners, the consulting group that conducted the research. The A.I. industry wants to help, and to profit: The start-ups OpenAI and Anthropic recently created enterprise versions of their chatbots designed for universities.

Generative A.I. is clearly here to stay, but universities are struggling to keep up with the changing norms. Now professors are the ones on the learning curve and, like Ms. Stapleton’s teacher, muddling their way through the technology’s pitfalls and their students’ disdain. …

The Times contacted dozens of professors whose students had mentioned their A.I. use in online reviews. The professors said they had used ChatGPT to create computer science programming assignments and quizzes on required reading, even as students complained that the results didn’t always make sense. They used it to organize their feedback to students, or to make it kinder. As experts in their fields, they said, they can recognize when it hallucinates, or gets facts wrong.

There was no consensus among them as to what was acceptable. Some acknowledged using ChatGPT to help grade students’ work; others decried the practice. Some emphasized the importance of transparency with students when deploying generative A.I., while others said they didn’t disclose its use because of students’ skepticism about the technology.

Most, however, felt that Ms. Stapleton’s experience at Northeastern — in which her professor appeared to use A.I. to generate class notes and slides — was perfectly fine. …

After filing her complaint at Northeastern, Ms. Stapleton had a series of meetings with officials in the business school. In May, the day after her graduation ceremony, the officials told her that she was not getting her tuition money back.

Editor’s Note: If you would like to receive a daily email with links to legal education posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/ny-times-professors-are-using-chatgpt-students-arent-happy-about-it.html

John C. McDonald (J.D. 2025, BYU), Note, Into the Sunset: Divorcing Families Need Their Slice of the TCJA Reversions, 50 BYU L. Rev. 531 (2024):

On its path to sufficiently offsetting its major cut to the corporate income tax rate in 2017, Congress turned to a surprising source for funds: the alimony support payments of recently divorced families. Alimony’s inclusion/deduction regime in §§ 71 and 215 of the Code allowed divorcing couples to reach mutually beneficial divorce agreements for over half a century until it was unceremoniously repealed by the Tax Cuts and Jobs Act of 2017 with a striking lack of satisfying legislative justifications. This Note suggests that in evaluating the impact of the repeal, Congress and others have failed to consider an important piece in the puzzle: the marriage bonus. The marriage bonus, which rewards some couples with better results for filing jointly rather than separately, scaled proportionally with the pre- TCJA alimony subsidy and resulted in most couples receiving inferior tax treatment by choosing to divorce. Now, after the repeal of the subsidy, couples have an even worse result when they choose to separate.

In the wake of the repeal of the alimony subsidy, some have praised the change’s improvements to the simplicity and consistency of the law, while others have mourned the loss of an important tax break that divorcing couples of the past leveraged to ease their transition out of the marriage bonus and into two separate and more expensive households. This Note analyzes both perspectives and suggests that the §§ 71 and 215 regime be reimplemented as part of the TCJA’s 2025 reversions with some minor improvements, including a compliance mechanism and a streamlined alimony calculation procedure. This restoration and improvement will return a much-needed benefit to recently divorced couples as they start their new lives.

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/into-the-sunset-divorcing-families-need-their-slice-of-the-tcja-reversions.html

The Columbia Journal of Tax Law has published a new issue (Vol. 15, No. 2 (Summer 2024)):

• Philip Hackney (Pittsburgh; Google Scholar), Keep Charitable Oversight in the IRS, 15 Colum. J. Tax L. 130 (2024)

• Leopoldo Parada (King’s College London; Google Scholar), Global Minimum Taxation: A Strategic Approach for Developing Countries, 15 Colum. J. Tax L. 187 (2024)

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/columbia-journal-of-tax-law-publishes-a-new-issue.html

This week, Doron Narotzki (Akron; Google Scholar) reviews a new paper by Jeffrey H. Kahn (Florida State) & Rebecca Roman (Gibson Dunn, Dallas), The Flip and Flop of Taxing Alimony, 16 Colum. J. Tax L. 131 (2025).

Kahn and Roman’s article, The Flip and Flop of Taxing Alimony, offers a rigorous and well-structured analysis of a significant yet often overlooked shift in U.S. tax policy: the treatment of alimony payments following the Tax Cuts and Jobs Act of 2017 (TCJA). Although the article focuses on the specific issue of alimony taxation, its analysis engages with foundational tax law concepts, including the ability-to-pay principle, progressive rate structures, the assignment of income doctrine, and the theoretical foundations of the income tax system. The authors approach the topic from multiple doctrinal, historical, and policy angles, resulting in a thorough and intellectually grounded examination.

The article begins with a clear introduction which sets out both the doctrinal change and the normative position the authors intend to defend. From there, the paper unfolds in four parts: (1) a historical account of alimony taxation in the United States; (2) a comparative review of the possible approaches to taxing alimony; (3) a detailed critique of the TCJA; and (4) a normative defense of returning to the prior deduction/inclusion regime. Each section builds logically on the prior, and the reader is never left unclear about the path the argument is taking.

The historical analysis part is especially strong. As someone with a deep appreciation for legal and tax history, I found this portion of the paper particularly engaging. The authors trace a century-long arc, beginning with Gould v. Gould in 1917 and extending through wartime revenue pressures, statutory changes in 1942 and 1984, and culminating in the TCJA’s reversal of course. This historical narrative is not only rich in detail but also instrumental in contextualizing contemporary policy decisions within a longer trajectory of doctrinal instability. Last, the integration of case law, legislative reports, and secondary commentary is thorough and carefully executed.

Building on this historical foundation, Kahn and Roman skillfully navigate the technical complexities of alimony taxation, building their analysis in the evolving statutory framework. The article offers a clear and in-depth treatment of the technical elements of alimony taxation. The authors lead the reader through the mechanics of the shifting tax regimes, including the roles of Code sections 71 and 215, the alimony recapture rules, the interaction with child support, and the implications for tax compliance and reporting. I personally found that the historical context developed earlier in the article enriches this technical discussion by illuminating how each regime emerged in response to evolving legal and fiscal pressures. Despite the technical aspects of the subject, the analysis remains accessible and precise throughout.

The policy discussion is one of the article’s strongest elements, offering a careful and well-rounded analysis that moves beyond surface-level argument and engages meaningfully with the broader implications of the current and prior tax regimes. While the authors make their clear case for restoring the deduction and inclusion regime, they also take opposing views seriously, particularly the work of Professors Davis, Soled, and Soled, and present their concerns regarding tax base erosion, collusion, and human capital theory with clarity and fairness. For instance, the authors challenge the human capital analogy to physical injury damages, arguing that alimony reflects mutual gains from marital contributions, not mere compensation for loss, thus justifying taxation to the recipient. The article’s responses are grounded in doctrine and informed by how these issues play out in real-world divorce negotiations, which is a very interesting read. Also, this kind of direct engagement with competing views makes the authors’ overall argument much more convincing. While the TCJA’s uniform treatment simplifies IRS enforcement, Kahn and Roman argue that the administrative burden of distinguishing alimony from child support is justified by the superior alignment with progressive taxation principles.

Furthermore, I found the article’s use of income tax theory to be highly engaging. The discussion of the Haig-Simons definition and the role of consumption as a proxy for tax base measurement adds real depth to the analysis. By framing alimony within the Haig-Simons framework, the authors not only critique the TCJA but also enrich broader debates about how income tax systems should measure consumption and allocate tax burdens across economic units. By examining how alimony fits (or fails to fit) within that framework, the authors move beyond doctrinal critique and offer a meaningful academic contribution. Their use of clear examples and well-chosen hypotheticals also stood out, providing a practical lens that helps make the theoretical discussion more accessible and useful.

Even readers without specific expertise in family law or alimony will find value in how the article uses this focused topic to explore broader questions about the structure and purpose of the income tax. Key policy considerations such as progressivity, fairness, administrative simplicity, and revenue impact are all addressed with much care and depth. The authors’ conclusion, which supports a return to the prior regime, is persuasive within the framework they present, though reasonable readers may come to different views depending on how they balance simplicity against equity or revenue concerns against taxpayer flexibility. By allowing parties to allocate the tax burden, the elective regime not only maximizes after-tax income but also serves as a practical tool to ease contentious divorce negotiations, potentially reducing litigation costs.

In sum, The Flip and Flop of Taxing Alimony is an excellent contribution to tax scholarship. It brings together historical context, technical precision, theoretical grounding, and normative analysis in a format that is both rigorous and accessible. Regardless of one’s views on the proper treatment of alimony payments, the article stands out for its clarity, depth, and its contribution to ongoing debates about the structure of the federal income tax. Students learning tax law would especially benefit from reading this piece. It demonstrates how a single issue can be analyzed through doctrinal, historical, economic, and policy perspectives, and it models how to connect statutory interpretation with larger theoretical concerns.

Here’s the rest of this week’s SSRN Tax Roundup:

• Reuven S. Avi-Yonah (University of Michigan Law School), Should the States Return to Worldwide Combined Reporting? (U of Michigan Law & Econ Research Paper Forthcoming)
• Aditya Biswas (Independent), Navigating the Complex Interplay: ITC and CSR Dynamics Over Time
• Joshua D. Blank (University of California, Irvine School of Law), Leigh Osofsky (University of North Carolina (UNC) at Chapel Hill), Introduction to Automated Agencies: The Transformation of Government Guidance (Cambridge University Press, forthcoming, 2025)
• William Boyd (UCLA School of Law), The Tax Struggle and Renewable Power (Tax Law Review vol. 79 no. 1 (2026); UCLA School of Law, Public Law Research Paper No. 25-20)
• Conor Clarke (Washington University in St. Louis – School of Law), Wojciech Kopczuk (Columbia University – Graduate School of Arts and Sciences – Department of Economics), Measuring Income and Income Inequality (Journal of Economic Perspectives, volume 39, issue 2, 2025)
• Jacob Cohen (University of Virginia School of Law), Crystals and Mud in International Taxation: Why the Principal Purpose Test’s Impact Will Not Meet Expectations (Virginia Law Review, Forthcoming 2026)
• Tessa Davis (University of South Carolina – Joseph F. Rice School of Law), Commodification, Precarity, and Identity: A Review of Professor Bridget Crawford’s Taxing Sugar Babies (109 Minn. L. Rev. Headnotes 59 (2025))
• Nicolin Decker (Independent), The NEXUS Token A Regulation D-Compliant Interchange Fee Mechanism for Infrastructure-Backed Public Finance Systems
• Eva Escribano (Universidad Complutense de Madrid), Spanish National Report for IFA Congress: Residency of legal entities for corporate income taxation (International Fiscal Association)
• Udonna Ezeani (Afe Babalola University, Ado-Ekiti), TAXING POWERS IN NIGERIA: CONSTITUTIONAL FRAMEWORK
• David Gamage (University of Missouri School of Law), Assessing the Tax Communications of E-Commerce Vendors, Part I (University of Missouri School of Law Legal Studies Research Paper No. 2025-22, 116 Tax Notes State 87 (April 14, 2025))
• David Gamage (University of Missouri School of Law), Beyond Blinders and Boomerangs: Assessing State Business Taxation (University of Missouri School of Law Legal Studies Research Paper No. 2025-21; 115 Tax Notes State 753 (March 17, 2025))
• Andrew Garin (University of Illinois at Urbana-Champaign), Emilie Jackson (Michigan State University), Dmitri Koustas (University of Chicago), Alicia Miller (Independent), The Impact of Third-Party Reporting on Tax Compliance: Evidence from Gig Workers
• Jeffrey H. Kahn (Florida State University College of Law), The Service’s Overgenerous Tax Treatment of Crowdfunding (Cardozo Law Review de novo 2025)
• Mamta Bhawanishanker Khandelwal (Raisoni Group of Institutions), INTERNATIONAL LAW AND INDIA’S TRANSFER PRICING REGIME: HARMONIZATION, ADAPTATIONS, AND FUTURE HORIZONS
• Aakash D Pratap (Independent), Canada-U.S. Trade Relations: Geography, Tariffs, and Strategic Diplomacy
• Michal Radvan (Masaryk University – Faculty of Law), Specifics of Tax Law Drafting on Selected Issues from the Czech Republic
• Vincent Ooi (Singapore Management University – Yong Pung How School of Law; Singapore Management University – Centre for Digital Law), Kerrie Sadiq (Queensland University of Technology – School of Accountancy), Australia’s Definition of Royalties: Overreach or Evolution? ((2024) 115(5) Tax Notes International 633-641)

Editor’s Note: If you would like to receive a daily email with links to tax posts on TaxProf Blog, email me here.

https://taxprof.typepad.com/taxprof_blog/2025/05/weekly-ssrn-tax-article-review-and-roundup-narotzki-reviews-the-flip-and-flop-of-taxing-alimony-by-k.html