Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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UC Law SF Hosts Tax Conference Today (Day 1)
UC Law SF hosts day 1 of the joint Association of Mid-Career Tax Scholars (AMT) and Experienced in Tax Conference (EITC) today: AMT Session 1 (9:00 AM): Ari Glogower (Northwestern; Google Scholar), Duties, Imposts, and Excises Discussant: Shayak Sarkar (UC-Davis; Google Scholar) Susan Morse (Texas; Google Scholar), A Tax Perspective on Executive Tariff Powers Discussant:
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UC Law SF Hosts Tax Conference Today (Day 1)
UC Law SF hosts day 1 of the joint Association of Mid-Career Tax Scholars (AMT) and Experienced in Tax Conference (EITC) today: AMT Session 1 (9:00 AM): Ari Glogower (Northwestern; Google Scholar), Duties, Imposts, and Excises Discussant: Shayak Sarkar (UC-Davis; Google Scholar) Susan Morse (Texas; Google Scholar), A Tax Perspective on Executive Tariff Powers Discussant:
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McCaffery: The Property-Tax Bundle Of Rights
Edward J. McCaffery (USC; Google Scholar), The Property-Tax Bundle of Rights, 2025 Mich. St. L. Rev. __ (reviewed by David Elkins (Netanya) here): This Article introduces the concept of a property-tax bundle of rights. There i s no property without tax; tax inevitably affects property rights. America has settled into an absolute conception of the property-tax bundle,
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McCaffery: The Property-Tax Bundle Of Rights
Edward J. McCaffery (USC; Google Scholar), The Property-Tax Bundle of Rights, 2025 Mich. St. L. Rev. __ (reviewed by David Elkins (Netanya) here): This Article introduces the concept of a property-tax bundle of rights. There i s no property without tax; tax inevitably affects property rights. America has settled into an absolute conception of the property-tax bundle,
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AI Gets Its First Law School A+s (And An A In Tax)
Update: Reuters, Artificial Intelligence Is Now an A+ Law Student, Study Finds Andrew Blair-Stanek (Maryland; Google Scholar), Donald G. Gifford (Maryland), Mark Graber (Maryland; Google Scholar), Guha Krishnamurthi (Maryland; Google Scholar), Jeff Sovern (Maryland; Google Scholar), Donald B. Tobin (Maryland; Google Scholar) & Michael P. Van Alstine (Maryland), AI Gets Its First Law School A+s:
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AI Gets Its First Law School A+s (And An A In Tax)
Update: Reuters, Artificial Intelligence Is Now an A+ Law Student, Study Finds Andrew Blair-Stanek (Maryland; Google Scholar), Donald G. Gifford (Maryland), Mark Graber (Maryland; Google Scholar), Guha Krishnamurthi (Maryland; Google Scholar), Jeff Sovern (Maryland; Google Scholar), Donald B. Tobin (Maryland; Google Scholar) & Michael P. Van Alstine (Maryland), AI Gets Its First Law School A+s:
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Harvard, Yale, And Others May Have Another Litigation Opportunity
Victor Thuronyi (IMF), Harvard, Yale, and Others May Have Another Litigation Opportunity, 187 Tax Notes Fed. 1241 (May 19, 2025): In this article, Thuronyi examines the constitutionality of a proposed exception to the excise tax on university endowments and the difficulties in determining whether an institution is truly “religious.” … Consider … the exception to
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Harvard, Yale, And Others May Have Another Litigation Opportunity
Victor Thuronyi (IMF), Harvard, Yale, and Others May Have Another Litigation Opportunity, 187 Tax Notes Fed. 1241 (May 19, 2025): In this article, Thuronyi examines the constitutionality of a proposed exception to the excise tax on university endowments and the difficulties in determining whether an institution is truly “religious.” … Consider … the exception to
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Zhang: The Forgotten Attribution Power
Alex Zhang (Emory; Google Scholar), The Forgotten Attribution Power, 135 Yale L.J. __ (2026): Economic inequality stands at record levels, and constitutional law haunts egalitarian reform. In 2024, the Supreme Court decided the latest contest: Moore v. United States rebuffed an attempt to sharply limit the federal taxing power, as a razor-thin majority upheld Congress’s
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Zhang: The Forgotten Attribution Power
Alex Zhang (Emory; Google Scholar), The Forgotten Attribution Power, 135 Yale L.J. __ (2026): Economic inequality stands at record levels, and constitutional law haunts egalitarian reform. In 2024, the Supreme Court decided the latest contest: Moore v. United States rebuffed an attempt to sharply limit the federal taxing power, as a razor-thin majority upheld Congress’s
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What Are The Real Tax Risks For Harvard?
Harvey P. Dale (NYU), Daniel J. Hemel (NYU; Google Scholar) & Jill S. Manny (NYU), What Are the Real Tax Risks for Harvard?, 187 Tax Notes Fed. 1447 (May 26, 2025): Although we focus here on Harvard — the principal target of Trump’s revocation threats so far — our analysis has implications for other nonprofit
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What Are The Real Tax Risks For Harvard?
Harvey P. Dale (NYU), Daniel J. Hemel (NYU; Google Scholar) & Jill S. Manny (NYU), What Are the Real Tax Risks for Harvard?, 187 Tax Notes Fed. 1447 (May 26, 2025): Although we focus here on Harvard — the principal target of Trump’s revocation threats so far — our analysis has implications for other nonprofit
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NYU Hosts A Virtual Discussion Today On Understanding Risks To Taxpayer Privacy
The NYU Tax Law Center hosts a virtual discussion on Understanding Risks to Taxpayer Privacy today (registration): Please join the Tax Law Center for a virtual discussion of the legal, privacy, and cybersecurity risks of unprecedented efforts to access, use, and share taxpayer data across government for purposes far beyond tax administration. Agenda: Fireside Chat:
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NYU Hosts A Virtual Discussion Today On Understanding Risks To Taxpayer Privacy
The NYU Tax Law Center hosts a virtual discussion on Understanding Risks to Taxpayer Privacy today (registration): Please join the Tax Law Center for a virtual discussion of the legal, privacy, and cybersecurity risks of unprecedented efforts to access, use, and share taxpayer data across government for purposes far beyond tax administration. Agenda: Fireside Chat:
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Elmendorf, Hubbard & Liscow: Policies To Reduce Federal Budget Deficits By Increasing Economic Growth
Douglas W. Elmendorf (Harvard), Glenn Hubbard (Columbia) & Zachary D. Liscow (Yale; Google Scholar), Policies to Reduce Federal Budget Deficits by Increasing Economic Growth: Could policy changes boost economic growth enough and at a low enough cost to meaningfully reduce federal budget deficits? We assess seven areas of economic policy: immigration of high-skilled workers, housing
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Elmendorf, Hubbard & Liscow: Policies To Reduce Federal Budget Deficits By Increasing Economic Growth
Douglas W. Elmendorf (Harvard), Glenn Hubbard (Columbia) & Zachary D. Liscow (Yale; Google Scholar), Policies to Reduce Federal Budget Deficits by Increasing Economic Growth: Could policy changes boost economic growth enough and at a low enough cost to meaningfully reduce federal budget deficits? We assess seven areas of economic policy: immigration of high-skilled workers, housing
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Lesson From The Tax Court: The Key Word In “Net Operating Loss”
Businesses fail. That’s a feature of capitalism, not a bug. Mark Twain discovered that when he lost his first fortune investing in a business that failed, the Paige Compositor. He not only lost his fortune but some say he also lost his sense of humor. Certainly his later works become more dystopian. See e.g. The
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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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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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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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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