Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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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…
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IBFD Opens Application for 2026 Doctoral Meeting of Researchers in International Taxation and Postdoctoral International Tax Forum (PITF)
The 2025 IBFD Academic Doctoral Meeting of Researchers in International Taxation (DocMIT) and Postdoctoral International Tax Forum (PITF) will be held on 29-30 January 2026 in Amsterdam. Applications are welcome until 1 September 2025 at academic@ibfd.org. Check out the brochure for more information regarding the procedure and requirements. What is it about?The purpose of the DocMIT…
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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 #3. The #1 paper is #448 among 12,137 tax papers in all-time downloads. [972 Downloads] Policies to Reduce Federal Budget Deficits by Increasing Economic Growth, by Douglas Elmendorf…
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Cambridge Conference On Legal Perspectives On The Development And Enactment Of Tax Policy
U.S. Tax Prof presentations at last week's conference on Perspectives On The Development And Enactment Of Tax Policy at the Centre for Tax Law at the University of Cambridge (call for papers): Victoria Haneman (Georgia; Google Scholar), Temporary Tax Law: Temporary legislation has been utilized before the founding era of American history, and Thomas Jefferson even…
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Weekly SSRN Tax Article Review And Roundup: Narotzki Reviews U.S. Tax Defense Measures And The International Law Of Countermeasures By Kuźniacki & Avi-Yonah
This week, Doron Narotzki (Akron; Google Scholar) reviews a new work by Błażej Kuźniacki (Lazarski; Google Scholar) & Reuven S. Avi-Yonah (Michigan; Google Scholar), Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures. In a time of growing tension and fragmentation in global trade and…
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Regulatory Mismatches In The United States And The European Union
Michael S. Knoll (Penn), Ruth Mason (Virginia; Google Scholar) & Wolfgang Schoen (Max Planck Institute), Regulatory Mismatches in the United States and the European Union(2025) This article explores regulatory mismatches, differences in regulations between different states, in the United States and the European Union, focusing on their differing approaches to market integration and regulatory diversity.…
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The Logic Of The Revenge Tax
Wei Cui (British Columbia; Google Scholar), The Logic of the Revenge Tax, 188 Tax Notes Fed. 37 (July 7, 2025): The United States possesses unique market power as a capital importer and provider of financial services to the rest of the world. It is thus in a strong position to raise revenue from foreign investors and users…
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Zelenak: The Brave New World of Automated Agency Guidance
Lawrence A. Zelenak (Duke; Google Scholar), The Brave New World of Automated Agency Guidance, 187 Tax Notes Fed. 2489 (June 30, 2025) (reviewing Joshua D. Blank (UC-Irvine; Google Scholar) & Leigh Osofsky (North Carolina; Google Scholar), Automated Agencies: The Transformation of Government Guidance (Cambridge University Press 2025): IntroductionIn a 1990 episode of the television sitcom Roseanne,…
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Polsky: Tax Weaponization Via Reconciliation
Gregg D. Polsky (NYU; Google Scholar), Something New Under the Sun: Tax Weaponization via Reconciliation, 187 Tax Notes Fed. 2483 (June 30, 2025): Tucked within the nearly 550 pages of the mammoth Senate Finance Committee’s reconciliation bill is a strange provision that will, if included in the final legislation, effectively destroy an entire industry without…
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The Comparative Law And Economics Of Term Limits For Academic Leadership
Jan M. Smits (Maastricht University; Google Scholar), The Comparative Law and Economics of Term Limits for Academic Leadership): This contribution discusses the arguments in favour and against strict term limits for full-time academic leaders (such as deans and rectors). It is argued that good reasons exist for limiting the time one can serve in such…
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Netanya Hosts 9th International Roundtable On Taxation And Tax Policy
Netanya hosts the 9th International Roundtable on Taxation and Tax Policy (program) today: Session I: International Taxation I: Pillar Two Chair: Yoram Margalioth (Tel Aviv University) Sagit Leviner (Ono Academic College; Google Scholar), The Two Pillar Reform in International Taxation of Multinational Corporations: Challenges and Policy Recommendations: The current international tax system, designed over a…
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Symposium: Teaching ADR, Mediation, Negotiation, And Client Counseling
Symposium, Teaching ADR, Mediation, Negotiation, and Client Counseling, 69 St. Louis U. L.J. 433-640 (2025): Debra Berman (South Texas) & Denise Peterson (South Texas), Pracademically Speaking: Incorporating Real-World Legal Practice into the Dispute Resolution Curriculum, 69 St. Louis U. L.J. 433 (2025) Christine Rollins (St. Louis), Integration of Mediation Skills as Required by the Nextgen Bar…
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Narotzki: When Debt Gets A Makeover, Taxes Follow
Doron Narotzki (Akron; Google Scholar), When Debt Gets a Makeover, Taxes Follow, 21 U.C. L. Bus. J. 85 (2024): The taxation of debt modifications is a complex and crucial area of tax law, significantly impacting both corporate finance and the broader economy. This article explores the complex legal and economic implications of modifying debt instruments,…
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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 #464 among 12,129 tax papers in all-time downloads. [953 Downloads] Policies to Reduce Federal Budget Deficits by Increasing Economic Growth, by Douglas Elmendorf…
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The NextGen Bar Exam Meets The NextGen Law Student: A Revised Approach To Legal Analysis
Scott Caron (Widener), The NextGen Bar Exam Meets the next Generation Law Student: A Revised Approach to Legal Analysis, 50 U. Dayton L. Rev. 43 (2024): The bar exam is changing, and soon. The National Conference of Bar Examiners (“NCBE”), the entity that supplies the bar exam for a majority of U.S. jurisdictions, is in…
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Weekly SSRN Tax Article Review And Roundup: Eyal Reviews Guttentag’s The New Law And Inequality Scholarship
This week, Mirit Eyal (Alabama; Google Scholar) reviews a new work by Michael D. Guttentag (Loyola-L.A), The New Law and Inequality Scholarship, 105 B. U. L. Rev. 897 (2025). In recent decades, both legal and economic scholarship have largely converged on the view that redistribution can be pursued through the tax system rather than through substantive…
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State Law Tests And Apprenticeships With The New Uniform Bar Exam?
Jeffrey Parness (Northern Illinois; Google Scholar), State Law Tests and Apprenticeships with the New Uniform Bar Exam?, 58 Creighton L. Rev. 1 (2024): A new approach to the Uniform Bar Exam (UBE), propounded by the National Conference of Bar Examiners (NCBE), will be available in July 2026. The current approach to UBE testing will no longer be…
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Narotzki & Shanan: We The People … Deserve Fair Taxes
Doron Narotzki (Akron; Google Scholar) & Tamir Shanan (College of Management; Google Scholar), We the People… Deserve Fair Taxes, 31 Cardozo J. Equal Rts. & Soc. Just. 573 (2025): In a world where economic inequality is deepening, tax law has emerged as one of the most powerful tools for shaping social justice. This article explores…
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Johnson: Cut $1 Trillion Of Governmental Fat Out Of Tax Expenditures
Calvin H. Johnson (Texas), Cut $1 Trillion of Governmental Fat Out of Tax Expenditures, 187 Tax Notes Fed. 2247 (June 23, 2025): In this report, Johnson argues that tax expenditures are always wasteful because only a fraction of their cost is passed on to the purported beneficiaries and that direct government dollars could accomplish the…
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Tax Law Scholarship: Introspection And Typology
Alice Pirlot (Catholic University of Louvain; Google Scholar), Tax Law Scholarship: Introspection and Typology, 8 British Tax Rev. 277 (2025): This article asks seemingly simple questions about tax law scholarship: What is it? To what extent does it differ from legal scholarship in other fields? Who is targeted by it? What are the main objectives…
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Bar Examination: A Verb, Not A Noun
Marsha Griggs (St. Louis; Google Scholar), Bar Examination: A Verb, Not a Noun, 77 Wash. U. J.L. & Pol’y 6 (2025): The legal profession, long steeped in tradition, is witnessing a transformative shift in the protocols for licensing new attorneys. Ironically, the proposed NextGen Bar exam has been a major catalyst in the transformation away…
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Tax Prof Panel On The International Tax Revolution
Society for the Advancement of Socio-Economics (SASE) hosts an annual conference today with a panel book salon on The International Tax Revolution: The past decade has witnessed the creation of a new International Tax Regime (ITR). The original ITR was created a century ago by the League of Nations based on a compromise reached in…
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Winning By Losing: The Strategy Of Adverse Private Letter Rulings
Noah Hertz Marks (North Carolina), Winning by Losing: The Strategy of Adverse Private Letter Rulings, 66 B.C. L. Rev. 659 (2025) (reviewed here by Blaine Saito (Ohio State; Google Scholar)): Every year, the Internal Revenue Service (IRS) issues hundreds of Private Letter Rulings (PLRs) responding to formal taxpayer inquiries about how tax law will apply to their…
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Soled & Todd: Hiring Biases Fostered Under The Code
Jay A. Soled (Rutgers; Google Scholar) & Timothy M. Todd (Liberty; Google Scholar), Hiring Biases Fostered Under the Code, 187 Tax Notes Fed. 2273 (June 23, 2025): In this article, Soled and Todd argue that current tax law gives U.S. employers a financial incentive to hire job applicants who have secured certain foreign visa statuses,…
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Private Equity’s Byzantine Tax Stand: An Untold And New Story Of Carried Interest
Domenico Imparato (University of Hamburg, UC-Berkeley), Private Equity's Byzantine Tax Stand: An Untold and New Story of Carried Interest, 7 Brit. Tax Rev. __ (2024): With the expansion of private equity’s footprint in the global economy has come scrutiny of its unique profit-sharing system, known as “carried interest”, which is perceived to enjoy favourable tax…