Author: Sloan Speck
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WSJ: The IRS Is Cracking Down on a Favorite Way the Ultrawealthy Pass On Money
Grantor retained annuity trusts (GRATs) are a longstanding staple of high-end estate planning. The basic structure is well-traveled: a grantor transfers appreciating assets to an irrevocable trust, retains an annuity for a fixed term, and—if the assets outperform the rate on the annuity—shifts excess appreciation to beneficiaries with comparatively little gift-tax cost. In the Wall…
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The Law Schools Closest to the NYT’s Top 50 Restaurants for 2026
The New York Times recently published its annual list of the 50 best restaurants in America. The Times, however, did not address a crucial question for faculty, staff, and students: which law schools are closest to these esteemed eateries? This post fills that crucial gap. Notable culinary hotbeds: New York Law School is the proximate…
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Dyrda et al.: Global Ripple Effects of Corporate Tax Reforms
Sebastian Dyrda (Toronto, Dept. Econ.), Guangbin Hong (Michigan State, Dept. Econ.), Muhammad Ali Sajid (Toronto, Dept. Econ.) & Joseph B. Steinberg (Toronto, Dept. Econ.), Global Ripple Effects of Corporate Tax Reforms, NBER Working Paper No. 34627 (July 2026):
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Call for Papers: UNC & ATPI Tax Literacy Summit
UNC’s Tax Law Program and the American Tax Policy Institute have issued a Call for Papers for their Tax Literacy Summit, co-sponsored by the ABA Section of Taxation and the Pittsburgh Tax Review. The Summit will be April 8 and 9, 2027, in Washington, D.C., and papers will be published in a symposium issue of…
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SSRN Review & Roundup: Marks Reviews Cauble’s Guiding Tax Return Preparers Informally
This week, Noah H. Marks (UNC) reviews a new work by Emily Cauble (Wisconsin), Guiding Tax Return Preparers Informally, __ Fla. Tax Rev. __ (forthcoming). Slightly more than 50% of individual income tax returns are prepared by paid tax return preparers. While their credentials and experience vary, these advisors are generally seen as comparatively sophisticated…
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Is the AI Boom Hollowing Out Corporate Tax Receipts?
In September 2026, the Congressional Budget Office reported a 25% year-over-year decline in corporate tax receipts, based on the first eleven months of the 2026 federal fiscal year. The absolute eleven-month decline was $96 billion—from $390 billion in FY 2025 to $294 billion in FY 2026—and comes on top of a 15% annual decline from…
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Is AI a Substitute for or a Complement to Billable Hours?
Generative AI promises to streamline routine legal work. Nevertheless, BigLaw clients are buying more of their lawyers’ time. At Bloomberg Law, Roy Strom reports that demand for BigLaw attorneys’ time rose 4.2% in the first half of 2026, compared with an historic norm of about 1.5%. These numbers follow significant demand growth for law firms’…
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OECD: MNE Responses to the Global Minimum Tax
Lucía Contreras, Felix Hugger & Tom Zawisza, MNE Responses to the Global Minimum Tax, OECD Tax’n Working Papers No. 77 (2026): The Global Minimum Tax (GMT), implemented in 2024, represents a significant change in the international tax system. This paper uses a difference-in-differences framework to assess the short-term impact of the GMT, including on effective…
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Everywhere Millionaires and the Tax Ninjas
America’s ultra-rich are concentrated in a handful of cities in states like New York, Illinois, California, Texas, and—increasingly—Florida. In today’s Second Gilded Age, this group garners disproportionate attention from the media, commentators, and policy entrepreneurs. Just below this elite tier, however, lies a less-studied cohort of approximately 3 million wealthy private-business owners, who collectively control…
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SSRN Review & Roundup: Gordon Reviews Clarke & Glogower’s The Indirect Taxes
This week, Jeff Gordon (Vanderbilt, Google Scholar) reviews Conor Clarke (Wash. U., Google Scholar) & Ari Glogower (Northwestern, Google Scholar), The Indirect Taxes, 102 Notre Dame L. Rev. __ (forthcoming 2027). From the founding era to Moore, most of the major constitutional tax law cases revolve around the question of how to define a “direct…
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A Retro Tax Reconstruction of Trump’s $5,000 Dividend
September’s two-day Republican midterm convention may not have moved the needle among voters, but it did yield an interesting (and incredibly expensive) policy proposal from President Trump. “It will be called the Trump dividend,” said the President, as he floated a $5,000 government payout for all adult Americans, if Republicans retain control of both houses…
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Quinnipiac Launches Three-Year Evening JD
Quinnipiac School of Law has relaunched its evening J.D. program as a new three-year curriculum, rather than the conventional four (or more) years. The innovative redesign “combines evening on-campus instruction, strategically placed online semesters and integrated bar preparation”—a holistic rethinking that differentiates this program from other accelerated part-time programs. Directing the program is taxprof Jenny…
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LSA 2027: Submissions Now Open!
Submissions are now open for the 2027 Global Meeting on Law and Society, which will be from June 22 through June 25 in Hong Kong, with a day of virtual sessions on June 26. The deadline for submissions is October 27, 2026, at 12 pm ET. The full call, including options for virtual participation, below…
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The Conversation: How “Egalitarian” Sweden Became More Comfortable with Wealth
Forbes counts 50 billionaires in Sweden, a country of 10.6 million. That’s 4.7 billionaires per million inhabitants—almost double the rate in the United States (2.7). This statistic is in some tension with the country’s “normalizing force” of Jantelagen, the Scandinavian cultural code that discourages outward displays of personal success. With the global rise of the…
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SSRN Review & Roundup: Gordon Reviews Eyal & Soled’s Betting on Tomorrow
This week, Jeff Gordon (Vanderbilt, Google Scholar) reviews Mirit Eyal (University of Alabama, Google Scholar) & Jay Soled (Rutgers Business School, Google Scholar), Betting on Tomorrow: Prediction Markets and the Tax Treatment of Event Contracts, 95 Geo. Wash. L. Rev. __ (forthcoming 2026). In a sense, prediction market contracts are a lawyer’s dream. They are…
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Politico: Trump Calls for Hollywood Tax Incentive
The limited expensing regime for qualified film or television productions expired at the end of 2025. Although a perennial tax extender until the Consolidated Appropriations Act, 2021 established the most recent sunset, the provision’s relatively low dollar cap left it somewhat anemic anyway. And with bonus depreciation generally triggered by release or broadcast, rather than…
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Inside Higher Ed: How Accreditation Changes Could Impact Professional Licensure
In late August, Department of Education staff suggested ending federal recognition of the American Bar Association’s accreditation authority. But how would losing federal recognition actually affect law schools, law students, and the bar admissions process? From Inside Higher Ed, the answer is classic law school: it depends. On the state, on the institution, on the…
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IMF: Taxing Cross-Border Services
In early August, the UN considered the text of an early protocol on the taxation of cross-border services, with a focus on expanded source-based taxation. A group of IMF coauthors points in a different direction in a working paper released just weeks before the August session, concluding that broader reliance on destination-based taxation may address…
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WSJ: Red States Are Racing to Roll Back Property Taxes
This fall brings a number of ballot measures that will test the intuition that inflation breeds tax revolts. In the Wall Street Journal, Sanai Hadiya Rashid and Will Parker report: North Carolina, Wyoming, Florida and Oklahoma all have some kind of property-tax limit or rollback on the ballot this November. This follows bills passed in more…
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Tariffs May Be Here to Stay—Even Under Democrats
It’s a myth that August is a quiet month for markets and politics. The same, apparently, is true for tariff policy and litigation, where August has brought a virtual heat dome of confluent events. The United States and Canada may be barreling towards “a full-blown trade war with no end in sight,” with potential legal…
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Inside Higher Ed on the Rapid Growth of Online and Hybrid Legal Education
Inside Higher Ed features a brief interview with Stephen Burnett, a former information technology dean at Seattle University School of Law, on the current state and future trajectory of remote and hybrid course delivery by law schools. (Burnett currently is at AllCampus, which provides services to universities in this area.) Some commentary, a link, and…
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Seabrooke & Stausholm: How TaxTech Rewires Global Wealth Chains
Leonard Seabrooke (Copenhagen Bus. Sch.) & Saila Stausholm (Copenhagen Bus. Sch.), How TaxTech Rewires Global Wealth Chains, Fin. & Soc’y (forthcoming 2026): Technological leaps in the algorithmic processing of information are providing financial actors with new opportunities for transnational financial and legal management that optimize asset allocation. Global professional service firms are actively developing TaxTech…
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Japan Considers a Rollover Rule for Business Divestitures
After tax-deferred spin-off expansions in 2017 and 2023, Japan is considering additional deferral rules for sales of ancillary businesses, provided the proceeds are reinvested in core activities. The changes are modeled—at least ostensibly—on similar tax reforms in Germany in early 2000s that were intended to unwind the postwar Deutschland AG model. And they’re structural cousins…
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SSRN Review & Roundup: Elkins Reviews Calderón Gómez’s Envy
This week David Elkins (Netanya, visiting Cincinnati) reviews Luís Calderón Gómez (Cardozo), Envy, 113 Va. L. Rev. _ (forthcoming 2027): In this week’s feature article, Professor Luís Calderón Gómez makes a provocative but carefully framed argument: if legal analysis takes welfare seriously, it cannot simply ignore envy because envy is morally unattractive. The article does…