Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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What Went Wrong In The Apple State Aid Case: Part 2 — Suggested Reforms
Ruth Mason (Virginia; Google Scholar) & Stephen Daly (King's College London; Google Scholar), What Went Wrong in the Apple State Aid Case and How to Fix It — Part 2: Suggested Reforms, 44 Va. Tax Rev. 421 (2025): This Article criticizes the reasoning of the European Commission and EU courts in the Apple state aid case and…
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Sovereignty, Outer Space, And Taxation
Erika Isabella Scuderi (Florida; Google Scholar), On Sovereignty, Outer Space, and Taxation, 104 Neb. L. Rev. ___ (2026): This article offers a comprehensive review of states' taxing powers in outer space. Beginning with an analysis of the legal status of airspace and outer space, the study assesses the resilience of traditional fiscal attachments, including residence-based…
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Reexamining Triangular B Reorganizations
Doron Narotzki (Akron; Google Scholar) & Tamir Shanan (Haim Striks; Google Scholar), Reexamining Triangular B Reorganization: Requirements and Potential Tax Traps or a Time to Revisit Its Favorable Application, 24 UC Davis Bus. L.J. 167 (2024): One of the most commonly executed changes in the structure of U.S. corporations is an exchange of stock of…
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OBBBA: Remittance Tax Goes From Highly Problematic To Barely There
Laura Snyder (Association of Americans Resident Overseas), OBBBA: Remittance Tax Goes From Highly Problematic to Barely There, 188 Tax Notes Fed. 31 (July 7, 2025): The various versions of One Big Beautiful Bill contained a tax on remittance transfers. This article compares the different versions of the tax as it was modified in each version of…
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Christians & Singer: Critical Questions In Tax Policy Analysis
Allison Christians (McGill; Google Scholar) & Samuel Singer (Ottawa; Google Scholar), The Role of Critical Questions in Tax Policy Analysis, 72 Can. Tax J. 825 (2024): This article explains what it means to ask critical tax questions, in order to show that critical tax studies are an essential component of good tax policy analysis. We demonstrate that, grounded in the…
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Revisiting Meritocratic Taxation
Erika Isabella Scuderi (Florida), Revisiting Meritocratic Taxation: This article examines the role of merit and desert in tax policy. These concepts are frequently invoked in political debates to support social and economic reforms. However, they are often infused with meanings that advance specific political—rather than policy—agendas, thereby threatening the very values they claim to uphold:…
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How To Turn 100 Million Workers Into Passive Shareholders
Joshua Cutler (Boise; Google Scholar), How To Turn 100 Million Workers Into Passive Shareholders: It is widely recognized that the United States retirement system has rapidly shifted away from defined benefit pension plans and towards defined contribution plans and Individual Retirement Accounts. Less recognized is the fact that most of these retirement plans now invest…
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The Persistent, Solvable Malady Of Law Student Multimedia Multitasking
Patrick Meyer (Detroit Mercy), The Persistent, Solvable Malady of Law Student Multimedia Multitasking, 69 St. Louis U. L.J. 125 (2024): In today’s world of popular and enticing social media platforms that constantly lure the attention of students away from course work, many professors find it difficult to keep the attention of their students. There is…
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Assessing Legal Writing Skills In The NextGen And AI World
Kimberly Y. W. Holst (Arizona State; Google Scholar), Assessing Legal Writing Skills in the NextGen and AI World 5 Proc.: Online J. Legal Writing Conf. Presentations 23 (2025): Given the convergence of rapidly developing generative artificial intelligence tools and the looming implementation of the NextGen Bar, it may be time to rethink whether the gold…
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The Top Five New Tax Papers
There is a bit of movement in this week’s list of the Top 5 Recent Tax Paper Downloads, with a new paper debuting on the list at #5. The #1 paper is #443 among 12,161 tax papers in all-time downloads. [981 Downloads] Policies to Reduce Federal Budget Deficits by Increasing Economic Growth, by Douglas Elmendorf…
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How 303(b)(3) Can Help Law Schools Mitigate Their Perennial Devices, Prices, Vices, And Crises
Kelly M. Gamble (Willamette), Breaking up with the Anti-Hero: How 303(b)(3) Can Help Law Schools Mitigate Their Perennial Devices, Prices, Vices, and Crises, 77 Me. L. Rev. 69 (2025): The American Bar Association’s issuance of Standard 303(b)(3) represents a pivotal shift compelling law schools to adapt their approach to the evolving needs of law students,…
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The Legal Ethics Of Generative AI
Andrew M. Perlman (Dean, Suffolk; Google Scholar), The Legal Ethics of Generative AI, 57 Suffolk U. L. Rev. 345 (2024): The legal profession is notoriously conservative when it comes to change. From email to outsourcing, lawyers are often slow to embrace new methods of delivering legal services and quick to point out potential problems, especially ethics-related concerns.…
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Addressing The Exclusion Of Undocumented Immigrants From Income Tax Benefits And Designing A Solution
Gabriela Amaral (J.D. 2024, Cardozo), Who Gets to Reap What They Sow? Addressing the Exclusion of Undocumented Immigrants from Income Tax Benefits and Designing a Solution, 30 Cardozo J. Equal Rts. & Soc. Just. 747 (2024): Support for immigration into the United States and for advancing the ways that people can gain legal status in…
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Weekly SSRN Tax Article Review And Roundup: Harpaz Reviews Regulatory Mismatches In The US And EU By Knoll, Mason & Schoen
This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Michael S. Knoll (Penn; Google Scholar) Ruth Mason (Virginia; Google Scholar), and Wolfgang Schön (Max Planck), Regulatory Mismatches in the United States and the European Union. Interstate commercial actors often face regulatory mismatches, which refer to differences in legal regulations between states. Regulatory mismatches are…
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Symposium: AI And Legal Education And Legal Profession
Symposium, AI and Legal Education and Legal Profession, 31 Int'l J. Legal Prof. 293-363 (2024): Amanda Head (Macquarie University) & Sonya Willis (Macquarie University; Google Scholar), Assessing Law Students in a GenAI World to Create Knowledgeable Future Lawyers, 31 Int'l J. Legal Prof. 293 (2024) Fife Ogunde (Government of Saskatchewan), Navigating the Legal Landscape: Large Language…
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Trends, Policies, And Considerations Of Artificial Intelligence Use In Law Review Authorship
Nachman N. Gutowski (UNLV; Google Scholar), Disclosing the Machine: Trends, Policies, and Considerations of Artificial Intelligence Use in Law Review Authorship, 2 Jacksonville U. L. Rev. __ (2025): The expanding role of artificial intelligence (AI) in legal research, writing, and scholarly creation pushes us to consider the need to challenge traditional notions of authorship and…
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The Solution To Pope Leo’s Tax Problems
Following up on my previous post, Will Tax Complexity Force Pope Leo To Renounce His U.S. Citizenship?: Libin Zhang (Fried Frank, New York), Papal-American Tax Problems and a Solution, 187 Tax Notes 2093 (June 16, 2025): On May 8 the College of Cardinals elevated the American-born Robert Francis Prevost to be the newest Pope of the…
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Colon: ETFs Join The Swap Fund Pantheon
Jeffrey M. Colon (Fordham), ETFs Join the Swap Fund Pantheon, ETFs have begun to challenge mutual funds as the dominant public pooled asset vehicle. Their constant liquidity, exposure to an ever widening range of investment strategies, and highly touted tax efficiency have driven the explosive growth in the assets under management of ETFs over the…
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Lawrence Reviews All The Campus Lawyers: Litigation, Regulation, And The New Era Of Higher Education
Frederick M. Lawrence (Georgetown; CEO, Phi Beta Kappa Society), Higher Education and the Law(yers), 49 J.C. & U.L. 113 (2024) (reviewing Louis H. Guard (Vice President & General Counsel, Hobart and William Smith Colleges) & Joyce P. Jacobsen (Former President, Hobart and William Smith Colleges; Google Scholar), All the Campus Lawyers: Litigation, Regulation, and the New Era of Higher…
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Athletic Performance And State Tax Rates: Why NBA Players Perform Worse In High-Tax States
Michael Conklin (Texas A&M; Google Scholar), Athletic Performance and State Tax Rates: Why NBA Players Perform Worse in High-Tax States, 21 Md. J. Bus. & Tech. L. ___ (2025): This Article presents the results of a novel empirical study measuring the impact of state income tax rates on professional athletic performance. While prior scholarship established…
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Singer & Christians: Critical Perspectives In Canadian Tax Law
Samuel Singer (Ottawa; Google Scholar) & Allison Christians (McGill; Google Scholar), Critical Perspectives in Canadian Tax Law, in Critical Conversations in Canadian Public Law (University of Ottawa Press 2025): The purpose of this article is to spotlight the role of critical tax law scholarship in Canada. We argue that critical perspectives are essential to identifying inequities…
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Ganor: The Curious Case Of Reverse Morris Trusts
Mira Ganor (Texas), The Curious Case of Reverse Morris Trusts, 19 Va. L. & Bus. Rev. 227 (2025): This Article analyzes the Reverse Morris Trust (RMT) transaction and shows that RMTs present a unique case of corporate governance. In an RMT the shareholders are positioned on both sides of the transaction while management is not,…
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SSRN Tax Professor Rankings
SSRN has updated its monthly ranking of 750 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database. Here is the new list (through July 1, 2025) of the Top 25 U.S. Tax Professors in two of the SSRN categories: all-time downloads…
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Avi-Yonah: Should Congress Reform The Accumulated Earnings Tax?
Reuven Avi-Yonh (Michigan; Google Scholar), Should Congress Reform the Accumulated Earnings Tax?, 187 Tax Notes Fed. 1493 (May 26, 2025): In this installment of Reflections With Reuven Avi-Yonah, Avi-Yonah explains why the shifting landscape of the corporate tax rate requires congressional intervention.
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Buchanan Reviews Morrow’s The Income Tax As A Market Correction
Update: With the Income Tax Under Sustained Attack, Professor Rebecca Morrow's Insights Are Especially Welcome Neil Buchanan (Sutherland School of Law, University College Dublin), “I’m Not a Distortion, You’re a Distortion!” (JOTWELL) (reviewing Rebecca Morrow (Wake Forest; Google Scholar), The Income Tax as a Market Correction, 77 U.C. L.J. ___ (2025)): The fundamental problem with orthodox…