Author: Shuyi Oei
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Pelikan: Toddlers, Investors, and Tax Policy
Lauren Shores Pelikan (U. of Missouri School of Law), Toddlers, Investors, and Tax Policy (January 16, 2026). 99 Southern California L. Rev. __ (forthcoming 2026), Available at SSRN: There is a continuing childcare crisis that worsens every year. Congress has historically used tax incentives aimed at parents and employers to try to alleviate the lack…
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Ryan: Checking In on Checking Out of the QTIP Regime
Kerry A. Ryan (Saint Louis Univ. School of Law), Checking In on Checking Out of the QTIP Regime (Jan. 20, 2026), available on SSRN. In this article, Ryan analyzes what the 2024 decisions in Estate of Anenberg and McDougall teach us about the tax consequences of terminating a qualified terminable interest property (QTIP) trust, and she highlights questions that remain unresolved.
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Schoen: Tariffs and the International Tax Order
Wolfgang Schoen (Max Planck), Tariffs and the International Tax Order (Jan, 12, 2026), Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2026-01, available on SSRN. Tariffs – or customs duties – have become a prominent feature of the international tax world in 2025. While their use had been restricted…
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Tax Analysts Taxing Issues Series: Corporate Tax Incentives and CAMT After the OBBBA
Tax Analysts’s next episode of Taxing Issues, “Corporate Tax Incentives and CAMT After the OBBBA” will be on Wednesday, January 28, 2026, from 2-3 pm ET. You can sign up for this free webinar at the above link. As companies assess the favorable corporate tax changes introduced by the One Big Beautiful Bill Act, some…
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Agrawal & Chen: State and Local Tax Policy in a Time of Telework
David R. Agrawal (UC Irvine) & Xinyu Chen (Michigan), State and Local Tax Policy in a Time of Telework (Dec. 23, 2025), available at SSRN State and local tax systems are constrained by the geographic location of individuals and economic activity. The rise of telework weakens this linkage by decoupling a worker’s state of residence…
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Galle, Gamage & Shanske: Correcting the Record: Responding to Some Legal Arguments About the 2026 Billionaire Tax Act
Brian D. Galle (UC Berkeley), David Gamage (Missouri), & Darien Shanske (UC Davis), Correcting the Record: Responding to Some Legal Arguments About the 2026 Billionaire Tax Act (Dec. 31, 2025, revised Jan. 9, 2026), available at SSRN If adopted by California voters in November of 2026, the 2026 California Billionaire Tax Act (CBTA) would impose…
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OECD Press Release and Webinar: 147 countries agree on key elements of a “side-by-side” global minimum tax arrangement
OECD Press Release: International community agrees way forward on global minimum tax package (Jan. 5, 2026) The 147 countries and jurisdictions working together within the OECD/G20 Inclusive Framework on Base Erosion and Profit Shifting (BEPS) have agreed on key elements of a package that charts a course forward for the co-ordinated operation of global minimum…
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Washington Post: California will miss billionaires when they’re gone
Following up on this morning’s blog post, WSJ: Threat of California Billionaire Tax Draws Criticism From Ultrawealthy: Washington Post Editorial Board: California will miss billionaires when they’re gone (Jan 1, 2026) Many progressives think of taxation the way teenage boys think about cologne: if some is good, more must be great. California already reeks of…
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Tax Notes Podcast: 2026 U.S. Tax Legislation Forecast
Tax Notes Talk Podcast: 2026 U.S. Tax Legislation Forecast (Dec. 31, 2025) Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2025 developments in U.S. tax legislation and speculates what may lie ahead in 2026.
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WSJ: Threat of California Billionaire Tax Draws Criticism From Ultrawealthy
Laura J. Nelson & Ben Glickman, Threat of California Billionaire Tax Draws Criticism From Ultrawealthy (Wall Street Journal, Jan. 1, 2026) High-profile tech investors criticized a proposed tax on the ultrawealthy in California in the final hours of 2025, while some of the state’s big-name billionaires took steps to create distance between themselves and the…
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WSJ: Billionaire’s Heirs to Pay $750 Million in Biggest-Ever U.S. Tax-Fraud Case
Gottfried & Maremont, Billionaire’s Heirs to Pay $750 Million in Biggest-Ever U.S. Tax-Fraud Case (Dec. 23, 2025, Wall Street Journal) The estate of the late billionaire Robert Brockman has reached an agreement to pay $750 million in back taxes and penalties, settling a civil suit that stemmed from what the government had called the biggest U.S. tax-fraud…
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Driessen: Senate OBBBA Deficit Denial Was Decades in the Making
Patrick Driessen, Senate OBBBA Deficit Denial Was Decades in the Making, 189 Tax Notes Federal 2013 (Dec. 22, 2025) The Senate used a current-policy baseline for the One Big Beautiful Bill Act (P.L. 119-21). That baseline suppressed $3.8 trillion each of revenue losses and deficit increases in the scoring of permanency for some temporary tax provisions first…
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Calderón Gómez: Is Tax “Law”?
Luís Calderón Gómez (Cardozo), Is Tax “Law”?, available on SSRN (Dec. 15, 2025), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5932577 Although taxation remains a hotly-contested issue in debates by both politicians and political theorists—over the optimal size of government; distributive (and sometimes corrective) justice; or even the legitimacy of current private property arrangements—taxation has been largely ignored by legal theorists, to…
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Daly: Using AI to Advance Democracy
Stephen Daly (King’s College London), Taxing Better: Using AI to Advance Democracy, available at SSRN (Dec. 17, 2025), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5932436 Artificial Intelligence (AI) is a threat to democratic norms. Machine learning bots have been used by malign forces to disrupt democratic processes. The literature as a result is replete with warnings! The goal of this project…
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Repetti: Private Equity, Health Calamity
James R. Repetti (Boston College), Private Equity, Health Calamity: How Our Tax Laws Aid Private Equity Investment in Hospitals and Nursing Homes, available at SSRN (Dec. 18, 2025), https://papers.ssrn.com/sol3/papers.cfm?abstract_id=5924964 The social welfare impact of investments by Private Equity funds (PEs) in various sectors of our economy is mixed due to the significant debt imposed on…
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NY Times: Should You Donate to Charity This Year or Wait? It Depends.
Ann Carrns (New York Times, Dec. 12, 2025), Should You Donate to Charity This Year or Wait? It Depends Thinking about donating to your favorite charity before the new year? You may want to consider tax law changes arriving in 2026 before deciding whether to make your gift in December or wait until next year.…
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Roberts, W(h)ither Regulation? Hither to the Tax System
Tracey M. Roberts (Samford), W(h)ither Regulation? Hither to the Tax System (November 25, 2025). Pace Environmental Law Review, Vol. 43, Issue 1, Fall 2025, Available at SSRN: https://ssrn.com/abstract=5810182 In a series of cases decided in the last three years, four delivered in 2024 alone, the U.S. Supreme Court has directed a withering gaze toward the federal…
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Hickman & Dooling: Delay, Politics, and Expertise in OIRA Tax Review
Kristin E. Hickman (Minnesota) & Bridget C.E. Dooling (OSU), Delay, Politics, and Expertise in OIRA Tax Review, Minnesota Legal Studies Research Paper 2025-53, Ohio State Legal Studies Research Paper No. 958, Available at SSRN: https://ssrn.com/abstract=5871302 The opening months of the second Trump administration have featured a wide range of changes to federal policy accomplished through presidential…
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Li & Nikolakakis: Offshore Tax Havens
Jinyan Li (Osgoode) & Angelo Nikolakakis (EY Law LLP), Offshore Tax Havens: An Intriguing Problem for Canadian Tax Law, 2025 Tax Notes Today, Int’l 231-17 (Dec. 4, 2025) The use of offshore tax havens by Canadians and multinational enterprises is an intriguing problem for Canadian tax law. This submission explains why that is the case…
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Chow, Huang, Hui & Shevlin: Judge Ideology and Corporate Tax Planning (SSRN)
Travis Chow (University of Hong Kong), Allen H. Huang (Hong Kong U. of Science and Technology), Kai Wai Hui (University of Hong Kong), Terry J. Shevlin (UC Irvine), Judge Ideology and Corporate Tax Planning (available at SSRN): We investigate whether judges’ political ideology affects corporate tax behaviors. We find firms engaging in less aggressive tax…
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OECD Corporate Tax Statistics, 2025
The OECD has released its latest data on corporate tax and the economic activities of MNEs worldwide, in its Corporate Tax Statistics 2025 Report: Corporate tax revenues have increased while statutory corporate tax rates have remained stable, according to new OECD data released today. The 2025 edition of OECD Corporate Tax Statistics shows that the share of…
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IFA Awards Programmes: Application Period Now Open
The Global IFA Permanent Scientific Committee invites applications for the following upcoming IFA Reseach Programmes and Awards: 🖋 The Global IFA Congress Award, recognising exceptional published research connected to one of the two Main Subjects of the Annual IFA Congress. There are no limitations on the age, location, or academic qualifications of the author(s). 🖋 The Mitchell B.…
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Herzfeld: Rationalizing the Post-OBBBA International Tax Rules, Part 2
Mindy Herzfeld (Florida), Rationalizing the Post-OBBBA International Tax Rules, Part 2, 120 Tax Notes Int’l 1416 (Dec. 1, 2025) The second Trump administration’s regulatory priorities for Treasury are twofold: implementation of the One Big Beautiful Bill Act (P.L. 119-21) and deregulation. The 2025-2026 priority guidance plan issued on September 30 — significantly pared down from prior years’ plans — highlights the shift…
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NTA Webinar on December 8, 2025: The Latest Developments in Carbon Taxation in the Rest of the World
National Tax Association Webinar (December 8, 2025, 1 pm Eastern): The Latest Developments in Carbon Taxation in the Rest of the World (Registration at the link)
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Gamage & Shanske, NCTI is the New GILTI, and States Should Still Conform
David Gamage & Darien Shanski, NCTI is the New GILTI, and States Should Still Conform, 117:12 Tax Notes State 799 (Sept 22, 2025) This essay continues our series on corporate profit shifting by analyzing how states should respond to the federal One Big Beautiful Bill Act, which transformed GILTI into the new Net Controlled Foreign…