Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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Avi-Yonah: Should Harvard And Other Large Nonprofits Be Taxed?
Reuven S. Avi-Yonah (Michigan; Google Scholar), Should Harvard and Other Large Nonprofits Be Taxed?, 187 Tax Notes Fed. 2299 (June 23, 2025): In this installment of Reflections With Reuven Avi-Yonah, Avi-Yonah examines justifications for exempting Harvard University and other large nonprofits from tax and argues that treating those organizations like large C corporations would not be such a bad…
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Wallace Reviews Taxation, Citizenship And Democracy In The 21st Century
Clint Wallace (South Carolina; Google Scholar), Book Review, 8 British Tax Rev. 296 (2025) (reviewing Taxation, Citizenship and Democracy in the 21st Century (Yvette Lind (BI Norwegian Business School; Google Scholar) & Reuven S. Avi-Yonah (Michigan; Google Scholar) eds. 2024)): The editors of this volume diplomatically challenge the “conservative amount of communication” between scholars focusing on taxation,…
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Lesson From The Tax Court: The New Regulation On Supervisory Approval Of Penalties
Section 6751(b) requires supervisory approval before the IRS can assess certain penalties. The statute is untouched by the recently enacted BBBA. In late December Treasury published these final rules on how the IRS must comply with the statute. Professor Caleb Smith shared some good thoughts on them on this Procedurally Taxing post. This Lesson is an…
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The Top Five New Tax Papers
This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list. The #1 paper is #476 among 12,124 tax papers in all-time downloads. [936 Downloads] Policies to Reduce Federal Budget Deficits by Increasing Economic Growth, by Douglas Elmendorf (Harvard), Glenn Hubbard (Columbia) & Zachary Liscow (Yale) [662 Downloads] …
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The Case For Fixing The Unprincipled Residence Tax Exemption
Samuel Singer (University of Ottawa) & Allison Christians (McGill; Google Scholar), The Case for Fixing the Unprincipled Residence Tax Exemption, 63 Osgoode Hall L.J. __ (2026): When Canada overhauled its income tax to include capital gains in 1972, lawmakers suddenly had to decide how to deal with personal home sales. After heated debate, they opted to…
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Guttentag: The New Law And Inequality Scholarship
Michael D. Guttentag (Loyola-L.A.), The New Law and Inequality Scholarship, 105 B.U. L. Rev. 897 (2025): An emerging body of scholarship is challenging the orthodoxy that the tax system rather than the legal system should be used to address inequality. This "New Law and Inequality Scholarship" argues for using law to address inequality for both…
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Avi-Yonah: OBBBA And The Next Tax Reform
Reuven S. Avi-Yonah (Michigan; Google Scholar), OBBBA and The Next Tax Reform: This paper compares OBBBA to the 1986 tax reform and suggests what a future US tax reform building on OBBBA might look like. The One Big Beautiful Bill Act (OBBBA) as passed by the Senate is far from an ideal tax reform. If…
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Institute For Austrian And International Tax Law Conference On The Impact Of Artificial Intelligence On Tax Law Kicks Off Today
The Institute For Austrian And International Tax Law hosts a conference on The Impact of Artificial Intelligence on Tax Law July 3-5 (program): This conference will compare different approaches to the governance and use of AI for tax purposes from the point of view of various stakeholders analyzing the unprecedented opportunities and risks inherent in…
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 78, No. 2 (Winter 2025): Susannah Camic Tahk (Wisconsin; Google Scholar), The Tax Separation of Powers, 78 Tax Law. 167 (2025) Bret Wells (Houston; Google Scholar), Ruminations on Negative Basis, Rev. Rul. 68-55, and Bigfoot Fallacies, 78 Tax Law. 225 (2025)
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Ajay Mehrotra Receives Prestigious Research Honors To Support His Latest Tax Book Project
Northwestern Law News, Professor Ajay Mehrotra Receives Prestigious Research Honors to Advance New Book Project: Ajay K. Mehrotra, the Stanford Clinton Sr. and Zylpha Kilbride Clinton Research Professor of Law at Northwestern Pritzker School of Law, and Affiliated Professor of History also at Northwestern University, has been selected as a Visiting Scholar at the Russell…
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Pittsburgh Tax Review Publishes New Issue
The Pittsburgh Tax Review has published Vol. 22, No. 2 (2025): Darien Shanske (UC-Davis; Google Scholar), Progressive State Tax Policy is Possible and Imperative, 22 Pitt. Tax Rev. 167 (2025) Adam B. Thimmesch (Nebraska; Google Scholar), The Dimensions of State Antipoverty Tax, 22 Pitt. Tax Rev. 179 (2025) Susannah Camic Tahk (Wisconsin; Google Scholar), A Tale of…
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Conjuring Markets: Valuation In Comparative International Economic Law
Toni Marzal (University of Glasgow), Conjuring Markets: Valuation in Comparative International Economic Law, 27 J. Int'l Econ. L. 353 (2024): This article focuses on the neglected relationship between market valuation and international economic law by comparing valuation practices in four subfields: international investment law, the law of the European Convention of Human Rights, international tax…
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Zelinsky: Private Foundations, DAFs, And The One Big Beautiful Bill Act
Edward A. Zelinsky (Cardozo), Private Foundations, DAFs, and the One Big Beautiful Bill Act, 187 Tax Notes Fed. 2135 (June 16, 2025): In this article, Zelinsky examines the One Big Beautiful Bill Act’s proposed progressive tax rate structure for large private foundations’ net investment income, pointing out that the bill doesn’t apply the same structure…
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Avi-Yonah: Is Section 899 A Valid Treaty Override?
Reuven S. Avi-Yonah (Michigan; Google Scholar), Is Section 899 A Valid Treaty Override?: [P][P]roposed section 899 clearly violates the non-discrimination provision of US tax treaties by subjecting a US branch of a foreign corporation to a higher tax rate than a domestic corporation. In addition, Section 899 amplifies the BEAT, which itself violates the non-discrimination…
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The Excise Tax On ‘Excessive’ Charity Compensation
Elaine Wilson (West Virginia; Google Scholar), The Fallacies Behind The Excise Tax On "Excessive" Charity Compensation, 56 Loy. U. Chi. L.J. 17 (2024): This Article examines the fundamental flaws in Section 4960 of the Internal Revenue Code, which imposes an excise tax on nonprofit executive compensation exceeding $1 million. The provision, enacted as part of…
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The Impact Of Legacy And Donor Admissions On A University’s Tax-Exempt Status
John R. Dorocak (Cal State-San Bernardino; Google Scholar), How Might a University's Tax-Exempt Status Not Be Revoked by the IRS for Legacy and Donor Admissions, Particularly after Students for Fair Admissions v. President & Fellows of Harvard College, and after Loper Bright Enterprises v. Raimondo?, 56 U. Tol. L. Rev. 1 (2024): Particularly after the Supreme Court…
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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. The #1 paper is #484 among 12,118 tax papers in all-time downloads. [929 Downloads] Policies to Reduce Federal Budget Deficits by Increasing Economic Growth, by…
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Gamage & Shanske: What States Should Do Now, Part I
David Gamage (Missouri-Columbia; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), Winter Is Coming: What States Should Do Now, Part I, 116 Tax Notes State 297 (May 5, 2025): This Article addresses the unprecedented fiscal challenges facing state governments as federal policy shifts threaten to create a perfect storm of revenue losses and increased service demands.…
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews What Are The Real Tax Risks For Harvard? By Dale, Hemel & Manny
This week, David Elkins (Netanya, Google Scholar) reviews Harvey P. Dale (NYU), Daniel J. Hemel (NYU) & Jill S. Manny (NYU), What Are the Real Tax Risks for Harvard?, 187 Tax Notes Fed. 1447 (May 26, 2025): President Trump has recently indicated that what he considers untoward practices at Harvard, along with those of other…
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Clarke & Glogower: Apportioned Direct Taxes
Conor Clarke (Washington University; Google Scholar) & Ari Glogower (Northwestern; Google Scholar), Apportioned Direct Taxes, 79 Tax L. Rev. ___ (2026): The Constitution requires that Congress apportion any “direct” tax among the states by population. This once-dormant provision is now the most important constitutional limitation on Congress’s taxing power. Last year, in Moore v. United States, the Supreme Court…
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ERISA’s Cure For The $1.4 Trillion Health Benefits Market
Amy B. Monahan (Minnesota; Google Scholar) & Barak D. Richman (George Washington; Google Scholar), Hiding in Plain Sight: ERISA's Cure for the $1.4 Trillion Health Benefits Market, 42 Yale J. on Reg. 234 (2025): Since 1974, the Employee Retirement Income Security Act (ERISA) has imposed fiduciary duties on those who manage and administer employee benefit…
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International Investment Agreements And The Global Minimum Tax
Vincent Beyer (UN Trade and Development), International Investment Agreements and the Global Minimum Tax: Of Treaty Troubles and Investment Incentives, 27 J. Int'l Econ. L. 241 (2024): Statutory and effective tax rates have witnessed a marked decline over the past decades, prompting international tax policymakers to grapple with the challenge of tax competition. The latest…
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Bearer-Friend: Race-Based Tax Weapons
Jeremy Bearer-Friend (George Washington; Google Scholar), Race-Based Tax Weapons, 14 U.C. Irvine L. Rev. 1067 (2024): In the United States, the term “poll tax” often refers to a very specific tactic of white supremacy: the use of tax policy to prevent voting by Black citizens. While “poll tax” is an accurate descriptor of these taxes,…
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The Global Effects Of Carbon Border Adjustment Mechanisms
Kimberly A. Clausing (UCLA; Google Scholar), Jonathan Colmer (Virginia; Google Scholar), Allan Hsiao (Stanford; Google Scholar) & Catherine Wolfram (MIT; Google Scholar), The Global Effects of Carbon Border Adjustment Mechanisms: We study carbon border adjustment mechanism (CBAM) policies, as currently being implemented by the EU and UK. Policy discussions have cited three motivations and one…
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Crawford: Six Ways Of Looking At The Climate Crisis
Bridget J. Crawford (Pace; Google Scholar), Six Ways of Looking at the Climate Crisis, 43 Pace Env’t L. Rev. ___ (2026): This Essay introduces the symposium issue of the Pace Environmental Law Review featuring six works presented at the March 2025 conference on "Taxation, the Environment, and Climate Change." This Essay identifies and explores three…