Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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Lokken: Income Source In A Digital Age
Lawrence Lokken (Florida), Income Source in a Digital Age: The source of income rules of the U.S. income tax laws require that income be sorted into a limited group of categories, including interest, dividends, rents, royalties, and gains on dispositions of property. The application of this sorting process to transactions in intellectual property has long…
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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 #2 and #5. [618 Downloads] IRS Officials' Stock Holdings and Corporate Tax Outcomes, by Michael Mayberry (Florida; Google Scholar), Eashwar Nagaraj (Florida) & Scott Rane (Florida; Google Scholar)…
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Tax Credits For Birth Mothers Post-Dobbs
Skyler Ligon (J.D. 2025, Washington University), Note, Giving Credit When You Are Due: Tax Credits for Birth Mothers Post-Dobbs, 102 Wash. U. L. Rev. 923 (2025): The Dobbs v. Jackson Women’s Health Organization decision has resulted in drastic consequences for women who become pregnant. Pregnant women living in states that have restricted access to abortion—and who…
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Taxing Cultural Endowments
Skyler E. Dykes (J.D. 2025, Washington University), Note, Taxing Cultural Endowments, 102 Wash. U. L. Rev. 1299 (2025): Scholars and politicians have long recognized that the charitable sector is not a monolith. And yet, America’s cultural industry, a significant portion of our charitable sector, has received little attention in tax policy scholarship. This Note takes the first…
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Weekly SSRN Tax Article Review And Roundup: Harpaz Reviews Azam’s The Global Minimum Tax And Intra Western Tax Competition
This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Rifat Azam (Interdisciplinary Center Herzliya; Google Scholar), The Global Minimum Tax and Intra Western Tax Competition, 44 Berkeley J. Int’l L. ___ (2026). Implementation of the OECD’s two-pillar solution, including the Global Minimum Tax, has been thrown into disarray following President Trump’s January 2025…
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Saito: Tax Regulations In A Loper Bright Light
Blaine G. Saito (Ohio State; Google Scholar), Tax Regulations in a Loper Bright Light, 28 Fla. Tax Rev. ___ (2025): The Supreme Court's decision in Loper Bright overturned Chevron deference, creating uncertainty in administrative law including tax regulation. While the majority opinion ended Chevron, it left ambiguous what standard of review courts should now apply—whether…
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Do Bar Exam Waivers Hurt Lawyer Quality?
Adam Chilton (Chicago; Google Scholar), Jacob Goldin (Chicago; Google Scholar), Kyle Rozema (Northwestern; Google Scholar), & Sarath Sanga (Yale; Google Scholar), Occupational Licensing and Labor Market Mobility: Evidence from the Legal Profession: We study how state occupational licensing requirements shape labor mobility across U.S. legal markets. Drawing on newly collected data, we link variation in…
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Important Developments In Federal Income Taxation (2024)
Edward A. Morse (Creighton; Google Scholar), Important Developments in Federal Income Taxation (2024): This outline covers significant developments in federal income taxation arising during the past year. It offers a selective treatment focusing on items likely to interest practitioners and advisors within a broad range of professional practices. Tax Court decisions (regular and memorandum) and appellate…
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The Global Minimum Tax And Intra Western Tax Competition
Rifat Azam (Interdisciplinary Center Herzliya; Google Scholar), The Global Minimum Tax and Intra Western Tax Competition, 44 Berkeley J. Int’l L. __ (2026): This article provides a critical and timely analysis of the Global Minimum Tax (GMT) in the context of intra-Western tax competition, following the recent executive order by President Trump disavowing prior U.S.…
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Choi Reviews Work Requirements And Child Tax Benefits
Jonathan Choi (USC, moving to Washington University; Google Scholar), Do Work Requirements Matter? New Evidence (JOTWELL) (reviewing Jacob Goldin (Chicago; Google Scholar), Tatiana Homonoff (NYU; Google Scholar), Neel Lal (Chicago), Ithai Lurie (Treasury Department; Google Scholar), Katherine Michelmore (Michigan; Google Scholar) & Matthew Unrath (USC; Google Scholar), Work Requirements and Child Tax Benefits (NBER Working Paper No. 32343…
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Has The Supreme Court Already Resolved How Loper Bright Applies To Section 7805 Tax Regulations?
Mitchell M. Gans (Hofstra), Has the Supreme Court Already Resolved How Loper Bright Applies to Section 7805 Regulations?, 187 Tax Notes Fed. 1069 (May 12, 2025): In a recent nontax case, the Supreme Court shed some light on a question that has been the subject of much debate in the tax community: whether, in applying Loper Bright, courts should give…
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10th Annual Texas Tax Faculty Workshop
The University of Texas School of Law hosts the Tenth Annual Texas Tax Faculty Workshop today: Bret Wells (Houston; Google Scholar), The Past and Future of Taxing “Incomes”, 104 N.C. L. Rev. ___ (2025) (with Clint Wallace (South Carolina; Google Scholar)) Commenter: Robert Peroni (Texas) Phyllis Taite (Oklahoma), Subsidies as Silent Spending: Tax Policy in DisguiseCommenter: Will…
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Marian: Not ‘Super Tax Havens’ After All
Omri Y. Marian (UC-Irvine; Google Scholar), Not ‘Super Tax Havens’ After All, 54 Intertax __ (2026): When crypto-assets were first introduced, tax experts worried that they might become “super tax havens”. With over a decade and a half of hindsight, this article questions whether this tax-enforcement doomsday scenario has materialized or may yet materialize. The…
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Gamage: Assessing State Business Taxation
David Gamage (Missouri-Columbia; Google Scholar), Beyond Blinders and Boomerangs: Assessing State Business Taxation, 115 Tax Notes St. 753 (Mar. 17, 2025): Karl A. Frieden’s article, “Wearing Blinders in the Debate Over Business’s ‘Fair Share’ of State Taxes” and his subsequent article, “The Boomerang Effect of the Business ‘Fair Share’ Tax Debate,” jointly contend that progressive…
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Raskolnikov: Law For The Rich
Alex Raskolnikov (Columbia; Google Scholar), Law for the Rich, 109 Minn. L. Rev. 1399 (2025) (reviewed by Young Ran (Christine) Kim (Cardozo; Google Scholar) here): With top incomes and wealth reaching historic highs, scholars and politicians have proposed new taxes and novel legal rules aimed at reversing the emergence of the new Gilded Age. Yet while new taxes…
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Curbing Multinational Digital Tax Avoidance With The General Anti-Avoidance Rule
Robert C. Bird (Connecticut; Google Scholar) & Kathryn Kisska-Schulze (Clemson; Google Scholar), Curbing Multinational Digital Tax Avoidance with The General Anti-Avoidance Rule, 63 Am. Bus. L.J. ___ (2026): Large multinational companies (MNCs) are increasingly leveraging the enormous value embedded in the global digital economy. This has resulted in numerous innovations; however, it las likewise resulted…
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Today’s Law, Society, And Taxation Panels
Today's Law, Society, and Taxation panels at the 2025 Law & Society Association Annual Meeting in Chicago: Taxation and the Constitution The crisis in democracy has its consequences inside the world of tax just as it does outside of tax law. The papers on this panel consider how the destabilization of democracy in all its…
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Velasco: Shortcomings Of Law School And Big Law
Julian Velasco (Notre Dame), Shortcomings of Law School and Big Law, 93 Fordham L. Rev. 1279 (2025): The present Colloquium, on Lawyers and Their Institutions, seeks to consider how various legal institutions shape lawyers’ professional norms, values, and conduct. In this Essay, I will consider the two legal institutions with which I have been most…
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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 #1 paper and a paper returning to the list at #5. [609 Downloads] IRS Officials' Stock Holdings and Corporate Tax Outcomes, by Michael Mayberry (Florida; Google Scholar), Eashwar Nagaraj (Florida) & Scott Rane (Florida;…
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Holden & Kisska-Schulze: The Taxable Future Of College Sports
John T. Holden (Indiana; Google Scholar) & Kathryn Kisska-Schulze (Clemson; Google Scholar), The Taxable Future of College Sports, 77 Ala. L. Rev. ___ (2025): College sports are changing. Historically the National Collegiate Athletic Association (NCAA) exercised a strong arm to prohibit college athletes from receiving any form of compensation. Today, a power shift is occurring…
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Kuehn & Joy: Measuring The Impacts Of Experiential Legal Education
Robert R. Kuehn (Washington University; Google Scholar) & Peter A. Joy (Washington University; Google Scholar), Measuring the Impacts of Experiential Legal Education, 73 J. Legal Educ. 598 (2024): Experiential legal education has become an essential component of the law school curriculum, emphasizing “learning by doing” through practical experiences in law clinics, externships, and simulation courses.…
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Today’s Law, Society, And Taxation Panel
Today’s Law, Society, and Taxation panel at the 2025 Law & Society Association Annual Meeting in Chicago: Justice, Equality, and Tax Law Diane Kemker (Southern; Google Scholar) (chair/discussant) The tax code is used in a vareity of ways to enact or support social goals that are not necessarily explicitly tied to economic ends. The papers in…
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Weekly SSRN Tax Article Review And Roundup: Kern Reviews Taxing Capital Gains At Death At A Rate Higher Than During Life By Rosenthal & McClelland
This week, Adam Kern (San Diego; Google Scholar) reviews Steve Rosenthal (Tax Policy Center) & Robert McClelland (Tax Policy Center; Google Scholar), Taxing Capital Gains at Death at a Rate Higher Than During Life, 186 Tax Notes Fed. 2417 (Mar. 31, 2025). In left-leaning tax policy circles, much energy has focused on taxing unrealized gains. There are…
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Law Jobs: Professional Regulation, The Division Of Legal Labor, And Institutional Change
Emily S. Taylor Poppe (UC-Irvine; Google Scholar), Law Jobs: Professional Regulation, the Division of Legal Labor, and Institutional Change, 93 Fordham L. Rev. 1217 (2025): Over the past century, changing economic conditions, technological advances, and shifts in the composition of the American workforce have transformed the organization of many fields. Meanwhile, the legal field has…