Author: Jon Endean
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Hanna: A New View of Taxation
Christopher Hanna (SMU) has recently published a new article, forthcoming in the University of Pennsylvania Journal of Business Law, titled “A New View of Taxation.” Here’s the abstract: Tax scholars have made a number of breakthrough discoveries in tax law going back to at least Thomas Hobbes and his observations on a consumption tax almost…
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N.Y. Times: Inside the Billionaires’ War Against California’s Proposed Wealth Tax
In the New York Times, Theodore Schleifer and Erin Griffith have a report, “Inside the Billionaires’ War Against California’s Proposed Wealth Tax.” From the article: Every Tuesday for the last few months, two dozen of the world’s richest people or their advisers hop onto a conference call and plan for war. The war is against…
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Hemel Presents “Death, Taxes, and Chicks” Today at Missouri
Daniel Hemel (NYU) will present Death, Taxes, and Chicks at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be only be open to guest participants live. Anyone who would like to join as a guest participant should email Professor Gamage directly for…
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Boston University Looking for Clinical Professor and Director of Tax Clinic
Boston University School of Law invites applications for the position of Clinical Associate Professor of Law and founding Director of the Tax Clinic. This position is a full-time, 12 month, non-tenure track clinical faculty position with a projected start date of July 1, 2027, and an expectation of opening the clinic for enrollment for the fall 2028 semester. For more details…
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TaxProf Blog Op-Ed: Galle et al. on “Tax Reform, Health Care Finance, and the Case for Prop 40”
This TaxProf Op-Ed on California’s Proposition 40 is by Brian Galle (UC Berkeley), David Gamage (Missouri), and Darien Shanske (UC Davis): Tax Reform, Health Care Finance, and the Case for Prop 40: California’s Billionaire Wealth Tax Brian Galle, David Gamage, and Darien Shanske Chocolate and peanut butter; tax reform and health care finance. In California’s…
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Morgan Presents “Substance Over Form as a Doctrine of Legal Characterization” Today at Missouri
Robin Morgan (Toronto) will present Substance Over Form as a Doctrine of Legal Characterization at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to join as a guest participant should…
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UCLA Law Call for Papers for the Business and Tax Roundtable for Upcoming Professors
The Lowell Milken Institute for Business Law and Policy at UCLA School of Law is pleased to announce its third annual Business and Tax Roundtable for Upcoming Professors (“BATRUP”). This in-person Roundtable will take place at UCLA from Sunday evening May 23rd through Tuesday afternoon May 25th. The program will feature commentary by invited senior scholars as well…
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Luke: ‘Transaction’ as Threshold, ‘Relevant’ as Directive in the Economic Substance Doctrine
In Tax Notes, Charlene Luke (Florida) critiques the dissenting opinion in the recent Tenth Circuit decision, Liberty Global Inc. v. United States, in which the majority ruled in favor of the government on the economic substance doctrine. From the piece: Much has already been written about Liberty Global, which involved a complex transaction called Project…
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Singh Presents “Weaponization of Taxation: Sovereign Tax Immunity as a National Security Tool” Today at Missouri
Vinita Singh (Minnesota) will present Weaponization of Taxation: Sovereign Tax Immunity as a National Security Tool at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to join as a guest…
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Section 351 Exchanges and ETFs
In Matt Levine’s Money Stuff newsletter from September 29, he highlights IRS Rev. Rul. 2026-20, which targets the use of section 351 in the context of exchange traded funds (ETFs). Here’s how Levine describes the so-called “heartbeat” transactions: The reason this works is that ETFs qualify as regulated investment companies, and as such, under section…
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Clarke Presents “Firms, Individuals, and the Income Distribution” Today at Missouri
Conor Clarke (Wash U) will present Firms, Individuals, and the Income Distribution, coauthored with Wojciech Kopczuk (Columbia), at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to join as a…
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Call for Tax Papers and Panels: Law & Society Annual Meeting
Neil Buchanan has issued his annual call for tax papers and panels for next year’s annual meeting of the Law & Society Association in Chicago, Illinois (June 22–26, 2027): The Law & Society Association (LSA) will host its next Global Meeting from June 22 to 26, 2027, in Hong Kong. For the 23rd year in a row, I…
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NYU Law to Host Event on Loper Bright and the Future of Tax Administration
The Graduate Tax Program at the NYU School of Law is hosting two panels on how the Loper Bright decision might affect judicial deference to Treasury Regulations in the Greenberg Lounge of Vanderbilt Hall (40 Washington Square South, New York, NY) on Thursday, October 8, 2026, from 1:00–3:30pm, with a reception to follow. Panel 1:…
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Choi Presents “AI Deceleration (or Acceleration) by Taxation” Today at Missouri
Jonathan Choi (Wash U) will present AI Deceleration (or Acceleration) by Taxation, coauthored with Paul Connell (Wisconsin), at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to join as a…
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Mayer: The Future of Nonprofit Regulation in the United States
Lloyd H. Mayer (Notre Dame) has a new piece published, The Future of Nonprofit Regulation in the United States: Three Dynamic Trends, in the Nonprofit Policy Forum (Oct. 27, 2025). Here’s the abstract: Nonprofit regulation in the United States is strongly influenced by society-wide political trends. This influence is especially evident today with respect to racial justice debates,…
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Kim & Erokhin: Algorithmic Tax Ownership
Young Ran (Christine) Kim (Cardozo) and Dmitry Erokhin (Vienna University of Economics and Business) have a new piece, Algorithmic Tax Ownership, published in volume 51 of the BYU Law Review. Here’s the abstract: Tax ownership is a crucial concept for determining tax liabilities, compliance, and enforcement. However, neither the courts nor the IRS has provided clear…
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Second Circuit Affirms Tax Court’s Judgment in Soroban
In previous posts, I have highlighted the ongoing litigation over the term “limited partner,” as defined in section 1402(a)(13) (the so-called “limited partner exception”). The Fifth Circuit, in its decision last month in K Alain, LLLP v. Commissioner, held that “the ordinary public meaning of [the] phrase [“limited partner”] is a partner who plays no…
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Harpaz Presents “Tax Sovereignty” Today at Pepperdine
Assaf Harpaz (Georgia) will present Tax Sovereignty at Pepperdine today as part of its Fall 2026 Pepperdine Tax Policy Workshop Series, hosted by Deanna Newton. If you would like to attend any of the workshops (and join our post-workshop lunch), please contact Deanna Newton.
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Calderón Gómez and Kane Present “Pigou Goes Abroad” Today at Missouri
Luís C. Calderón Gómez (Cardozo) and Mitchell Kane (NYU) will present Pigou Goes Abroad (reviewed here by Jon Endean) at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to join…
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Cauble: Channels of Tax Law (Mis)Information
Emily Cauble (Wisconsin) has recently published a new piece, Channels of Tax Law (Mis)Information, 2026 U. Ill. L. Rev. 543. Here’s the abstract: This Article sheds light on a pervasive phenomenon. In a variety of contexts, third parties provide information about tax law to taxpayers. The information provided by these third parties may guide the…
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Oh: Does the Corporate Tax Still Distort Organizational Governance?
Jason Oh (UCLA) recently published a new piece, Does the Corporate Tax Still Distort Organizational Governance?, 22 N.Y.U. J.L. & Bus. 69 (2025). Here’s the abstract: To what extent does the tax system distort the organizational governance of business entities? For private entities, the connection between tax treatment and governance is weak. Tax and governance can be…
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Tax Workshop Clearinghouse: A Reminder and a Renewed Invitation
Earlier this year, TaxProf Blog announced a Tax Workshop Clearinghouse, a resource designed to make it easier for workshop and conference organizers to identify scholars with current works in progress, while also giving tax scholars a simple way to indicate that they have projects that would benefit from presentation and feedback. The initial response was…
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Appleby Presents “Privatized Tax Enforcement: State False Claims Acts and the Constitutional Limits of Outsourced Revenue Collection” Today at Missouri
Andrew Appleby (Tennessee) will present Privatized Tax Enforcement: State False Claims Acts and the Constitutional Limits of Outsourced Revenue Collection at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to…
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Applications Open for NYU Tax VAP
Applications are open for candidates for the Visiting Assistant Professor of Tax Law in the Graduate Tax Program at NYU. The position is a one-year term appointment with possibility of renewal for a second year. The position is not a tenure-track appointment. For more information, please see this link. Applicants can apply here and should…
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New Report by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released a new report, Report Number 1532 on Application of the Corporate Alternative Minimum Tax to Liabilities and to Distressed Taxpayers: [This Report] comment[s] on the application of the corporate alternative minimum tax (“CAMT”) under Sections 55, 56A, and 59 of the Internal Revenue Code…