Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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IRS Officials Trade On Confidential Tax-Related Information And Impact Tax Enforcement Outcomes
Cato Institute: IRS Officials’ Stock Holdings and Corporate Tax Outcomes, by Michael Mayberry (Florida; Google Scholar), Eashwar Nagaraj (Florida; Google Scholar) & Scott G. Rane (Florida; Google Scholar): The IRS plays an important role in improving corporate transparency and encouraging corporations to act in the best interests of their shareholders and other stakeholders. The agency makes…
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Tax Prof Richard Winchester Helps Students Build Database To Measure Impact Of FHA Racial Segregation On Homeowners
Following up on my previous post, Tax Prof Named Urban Studies Scholar To Research Why The FHA Funded An All-Black Community Despite A Whites-Only Policy: Tulane Murphy Institute, Building A Database for Scholarly Inquiry on Racial Segregation: A team of Murphy students spent a portion of the semester helping to build a database to support…
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Gamage, Brooks & McCaffery: Fixing The Personal Tax System Despite Constitutional Constraints
David Gamage (Missouri-Columbia; Google Scholar), Jake Brooks (Fordham; Google Scholar) & Edward J. McCaffery (USC; Google Scholar), Moore Questions, Some Answers: Fixing the Personal Tax System Despite Constitutional Constraints, 28 Fla. Tax Rev. ___ (2025): Moore v United States was expected to rule on the constitutional necessity of the tax-law realization requirement originating from Eisner v Macomber, a…
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Turley: New Study Raises Concerns Over Universal Basic Income Plans
Jonathan Turley (George Washington; Google Scholar), New Study Raises Concerns Over Universal Basic Income Plans: In my forthcoming book, Rage and the Republic: The Unfinished Story of the American Revolution, I explore how the American republic can survive in the 21st Century given unprecedented economic, technological, and political changes. The book addresses the increasing calls for…
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The Top Five New Tax Papers
There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with new papers debuting on the list at #4 and #5. [409 Downloads] Hyosung Corp.: The Tax Treaty-Domestic Tax Law Interaction, by Dhruv Janssen-Sanghavi (Maastricht; Google Scholar) [377 Downloads] Rule of Law v. Rule of Power:…
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Weekly SSRN Tax Article Review And Roundup: Endean Reviews Raskolnikov’s A New View Of Formal Equality And A Case For Predistribution
This week, Jon Endean (Brooklyn; Google Scholar) reviews a new work by Alex Raskolnikov (Columbia), A New View of Formal Equality and a Case for Predistribution, 17 J. Legal Analysis ___ (2025). Many scholars and politicians have decried increasing levels of inequality in the United States in recent decades, and while calls for increased taxes…
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Back To The Future: How The Pre-OECD Global Tax Landscape Offers Lessons For Today
Steven Dean (Boston University), Erin Ryu (J.D. 2026, Boston University) & Danna Lopez-Flores (J.D. 2026, Boston University), Back to the Future: How the Pre-OECD Global Tax Landscape Offers Lessons for Today: At a time when developing countries need to ramp up investment to achieve development and climate goals, tax revenue is particularly urgent. A global…
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Raskolnikov: A New View Of Formal Equality And A Case For Predistribution
Alex Raskolnikov (Columbia), A New View of Formal Equality and a Case for Predistribution, 17 J. Legal Analysis ___ (2025): A long-held egalitarian view is that formal equality-the absence of formal legal distinctions based on the material resources of individuals-is regressive. If legal rules are the same for the rich and the poor, the rich…
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The Tax Trap Of Israeli Mutual Funds
Ronen Perry (Haifa; Google Scholar), The Tax Trap of Israeli Mutual Funds One of the most troubling phenomena for Israeli retail investors is the tax trap that domestic investment companies regularly set for them. The problem can be described in a nutshell as follows: An investment company establishes a new mutual fund for investment in…
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The Worthlessness Deduction for Partnership Interests: An Unguided Missile
Walter D. Schwidetzky (Baltimore), The Worthlessness Deduction for Partnership Interests: An Unguided Missile, 183 Tax Notes Fed. 461 (Apr. 15, 2024): In this article, I explain how a disjuncture between the provisions governing capital loss treatment and those governing ordinary loss treatment has created tax planning opportunities for a partner taking a worthlessness deduction for…
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Lederman & Lawsky: Decoding Deductions
Leandra Lederman (Indiana; Google Scholar) & Sarah B. Lawsky (Northwestern; Google Scholar), Decoding Deductions: This Article provides new insights into the federal income tax deductions available to individuals. First, after organizing individuals' deductions into the familiar categories of expenses versus losses and three types of activities that individuals engage in, the Article shows the advantages…
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Lemar: Building Builders’ Clinics
Anika Singh Lemar (Yale), Building Builders' Clinics: In some significant part because of the structure of American law, both the private and public sectors underproduce crucial public and private infrastructure in the United States today. Housing, clean energy technology, sewers, and rail, for example, are all exceedingly politically difficult to plan and, not unrelatedly, expensive…
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Poor People Are More Likely Than Rich People To Support International Redistribution
Yehonatan Givati (Hebrew University), Income and Preferences for International Redistribution: Theory and Evidence, 22 J. Empirical Legal Stud. ___ (2025): How do preferences for international redistribution vary with income across countries? And within countries, are poor people more or less likely than rich people to support international redistribution? I develop a simple model which includes…
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Kern: Does The U.S. Exception Threaten Pillar Two?
Adam Kern (San Diego; Google Scholar), Does the U.S. Exception Threaten Pillar Two?, 188 Tax Notes Fed. 387 (July 21, 2025): The G7’s proposal to recognize GILTI as a qualifying IIR [Income Inclusion Rule] is a milestone in the project of establishing a global minimum tax. If accepted, it would establish two minimum tax regimes: one…
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Lesson From The Tax Court: The Difference Between Tax Assessments And Tax Liabilities
When I teach Tax Practice and Procedure, my students regularly confuse the concepts of assessment and liability. They think that taxpayers have no liabilities until-and-unless the IRS properly assesses those liabilities. No assessment, no liability! And if the IRS abates an assessment, why that nukes the liability as well. No assessment, no liability! The taxpayers…
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Zero-Sum Environmentalism: Competing Tax Incentives For Solar Farms And Wildlife Conservation Land
Nathaniel Swigart (J.D. 2025, North Carolina), Comment, Zero-Sum Environmentalism: Competing Tax Incentives for Solar Farms and Wildlife Conservation Land, 103 N.C. L. Rev. 803 (2025): In a rush to woo solar companies into the state, North Carolina has enacted generous tax incentives for solar panels. While these tax incentives have resulted in North Carolina being…
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The Top Five New Tax Papers
There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new #1 paper, a new paper debuting on the list at #4, and a paper returning to the list at #5. [351 Downloads] Hyosung Corp.: The Tax Treaty-Domestic Tax Law Interaction, by Dhruv Janssen-Sanghavi…
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Aprill & Horwitz: Fiduciaries, Constituencies, And The Duty Of Loyalty In Modern Nonprofits
Ellen P. Aprill (Loyola-L.A.; Google Scholar) & Jill R. Horwitz (UCLA; Google Scholar), Fiduciaries, Constituencies, And The Duty Of Loyalty In Modern Nonprofits, Nonprofit Policy Forum: A fiduciary of a charity has a fundamental duty to act in good faith and in a manner the fiduciary reasonably believes to be in the best interests of…
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Scuderi’s Sovereignty, Outer Space, And Taxation
This week, Blaine G. Saito (Ohio State; Google Scholar) reviews a new work by Erika Isabella Scuderi (Florida), Sovereignty, Outer Space, And Taxation, 104 Neb. L. Rev. ___ (2026). Space is a new frontier of commercial activity. Companies now launch satellites for profit. Others seek to travel to the moon, Mars, and beyond perhaps for…
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Examining The Circuit Split On Conservation Easements
Harry A. Mullen IV (J.D. 2025, Georgia State), Tax Evasion and Judicial Oversight: Examining the Circuit Split on Conservation Easements, 41 Ga. St. U. L. Rev. 457 (2025): Conservation easements have long been an attractive tool for those seeking to minimize their tax bill. After all, it is a low-cost method of getting a sizeable tax…
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Pay Taxes and Get Deported: Undocumented Immigrants and Tax Privacy
Samuel D. Brunson (Loyola-Chicago; Google Scholar), Pay Taxes and Get Deported: Undocumented Immigrants and Tax Privacy, The IRS has more information about more Americans than any other agency in the United States. Historically, other administrative agencies have targeted that IRS data to pursue their mandates or, at times, to pursue their enemies. In the wake of a…
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Divorcing Families Need Their Slice Of The TCJA Reversions
John C. McDonald (BYU), 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.…
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How Casebooks Shape The Apprehension And Meaning Of Law
Sam Williams (Idaho), Authorship by Omission: How Editorial Choices in Casebooks Shape the Apprehension and Meaning of Law, 58 Ind. L. Rev. 335 (2024): The unique internal workings of the legal mind are a point of pride for the profession. But do those internal machinations reflect, and possibly reinforce, biases that ought to be examined,…
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Transnationalization Of Legal Education: A Confluence Of Multiple Factors
Md. Rizwanul Islam (North South University; Google Scholar), Transnationalization of Legal Education: A Confluence of Multiple Factors, 69 St. Louis U. L.J. 99 (2024) (reviewing Bryant Garth (UC-Irvine; Google Scholar) & Gregory Shaffer (UC-Irvine; Google Scholar), The Globalization of Legal Education: A Critical Perspective (Oxford University Press 2022)): Legal education across many parts of the…
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Parsons: Taxing Social Data
Following up on my previous post, Valuing Social Data [124 Colum. L. Rev. 993 (2024)]: Amanda Parsons (Colorado; Google Scholar), Taxing Social Data: Data about people, or social data, powers the digital economy. Social data allows companies to predict and modify human behavior, producing economic value for themselves and wealth for their investors. Tax law…