Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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Kim Presents “Algorithmic Tax Ownership” Today At Georgia
Christine Kim (Cardozo) presents Algorithmic Tax Ownership (co-authored with Dmitry Erokhin) at Georgia today, as part of its Tax Policy Colloquium Series hosted by Assaf Harpaz: Tax ownership is a crucial concept for determining tax liabilities, compliance, and enforcement. However, neither the courts nor the IRS have provided clear guidance on how to analyze it. Since the Supreme Court first outlined a
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USC: 2026 Poverty Law Conference: Scholarship, Pedagogy, and Community in a Time of Attacks on the Vulnerable
Professors Ariel Jurow Kleiman and Clare Pastore hosted the 2026 Poverty Law Conference: Scholarship, Pedagogy, and Community in a Time of Attacks on the Vulnerable on February 20-21, 2026, at USC. The panels were as follows: Thank you to Mira Dalpe and Angela Houff for their work making the conference possible.
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Caines Presents “Understanding the Taxation of Cryptocurrencies” Today at Toronto
Ian Caines presents Understanding the Taxation of Cryptocurrencies at Toronto, as part of its James Hausman Tax Law and Policy Workshop Series hosted by Ben Alarie: Cryptocurrencies and related electronic assets can be a mysterious area for tax practitioners, raising potentially novel tax issues. However, unlike in other areas that a tax professional might encounter, tax uncertainties arise not so
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Love: Taxing Complexity
Michael Love (Columbia), Taxing Complexity: Complex business structures have overwhelmed U.S. tax enforcement, leaving trillions of dollars of business activity beyond the reach of meaningful oversight. This article develops a new theoretical framework to understand and address the social costs of this complexity, identifying two distinct channels of harm. Not only does complexity shield a
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Kern Presents “Buy or D.I.Y.: Home Production and the Income Tax” At UCLA
Adam Kern (San Diego) presents Buy or D.I.Y.: Home Production and the Income Tax today at UCLA, as part of its Colloquium on Tax Policy and Public Finance: The income tax aspires to be comprehensive—a tax on “all income, from whatever source derived.” Yet every year, trillions of dollars of productive activity escapes taxation with
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Clarke Presents “What Made Income Taxes Possible” Today At Duke
Conor Clarke (Washington University) presents What Made Income Taxes Possible (co-authored with Edward Fox and Wojciech Kopczuk) at Duke today, as part of its Tax Policy Seminar hosted by Larry Zelenak: Why do governments impose taxes on “income” rather than (and in addition to) other things? Large literatures in economics, history, and political science answer
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Blank Presents “Audit Guides & The Administrative State” Today at Boston College
Joshua Blank (UC Irvine) presents Audit Guides & The Administrative State (co-authored with Leigh Osofsky (UNC)) at Boston College today at 5pm ET as part of its Tax Policy Collaborative hosted by James Repetti and Diane Ring:
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Love Presents “Taxing Complexity” Today at San Diego
Michael Love (Columbia, SSRN) presents Taxing Complexity at San Diego today as part of its Tax Law Speaker Series.
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Morrow: The Income Tax as a Market Correction
Rebecca Morrow (Wake Forest), The Income Tax as a Market Correction, 76 UC Law SF L.J. 1373 (2025): I confess. As a tax professor, it has long hurt my feelings that economists label tax as a market distortion. My field is summed up as an impurity on the otherwise pristine complexion of the economist’s pure
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Book of the Week
John Fabian Witt, Allen H. Duffy Class of 1960 Professor of Law and Professor of History at Yale brings us The Radical Fund: How a Band of Visionaries and a Million Dollars Upended America, which tells the tale of how a young heir, Charles Garland, used his fortune to found the American Fund for Public
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Brennan Presents “The Government’s Gift to Givers: Donating Appreciated Stock” Today at Toronto
Thomas J. Brennan (Harvard) presents The Government’s Gift to Givers: Donating Appreciated Stock at Toronto, as part of its James Hausman Tax Law and Policy Workshop Series hosted by Ben Alarie: Under Section 170(e), taxpayers can deduct appreciation without paying tax on this gain. This double benefit is well understood. Yet this Article frames the tax benefit somewhat
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Bagenstos: “Slush Funds” and Congress’s Power of the Purse
Sam Bagenstos (Michigan) has posted “Slush Funds” and Congress’s Power of the Purse on SSRN. Here is the abstract: If there’s one point on which everyone agrees in appropriations law, it’s that “slush funds” are bad. In the appropriations context, people tend to use the term to refer to financing mechanisms that enable the Executive
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Galle: How to Tax the Ultrarich
Brian D. Galle (UC Berkeley), How to Tax the Ultrarich (Roosevelt Institute Jan. 2026) (fact sheet): This report proposes a new tax, the Fair Share Tax (FAST), on very wealthy households. The FAST is imposed at sale like the current capital gains tax, but adds an interest-like extra tax on taxpayers who hold their assets
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 11 (February 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron:
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Consumer Credit and the Incidence of Tariffs: Evidence from the Auto Industry
Kristine W. Hankins, Morteza Momeni, and David Sovich, Consumer Credit and the Incidence of Tariffs: Evidence from the Auto Industry, American Economic Review, 116 (2): 627–73 (2026): Captive finance subsidiaries create a channel for trade policy to affect consumer credit. Examining the impact of the Trump administration’s metal tariffs on captive automobile lenders, we find that
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Mazur: Modernizing the IRS in the Age of AI
Orly Mazur (SMU), Modernizing the IRS in the Age of AI, 45 Va. Tax Rev. 182 (2025): Artificial intelligence (AI) offers powerful tools for modernizing tax administration, from automating audits and improving fraud detection to enhancing taxpayer services. But if deployed prematurely, AI risks entrenching the very flaws it aims to fix. The Internal Revenue
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Rosenzweig: Stateless Public Goods
Adam H. Rosenzweig (Washington University), Stateless Public Goods, 74 Kan. L. Rev. 235 (2025): The rise of the digital economy has proven to be one of the most significant developments in modern economic history, not only due to its explosive economic growth but also for its potential to improve the quality of life for billions
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Bringing the State Back Into the Public Finance of Developing Countries
Anders Jensen (Harvard) and Jonathan L. Weigel (Berkeley), “No Taxation Without Administration: Bringing The State Back Into The Public Finance Of Developing Countries” (NBER January 2026): The empirical economics literature on taxation in developing countries has centered on the importance of third-party information for enforcement. Yet, while surely a long-run objective, leveraging such information remains
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New Evidence on the Elasticity of Taxable Income
Xavier Dufour, Pierre-Carl Michaud, and Michael G. Smart, “Salience and the Elasticity of Taxable Income: Evidence from Top-bracket Tax Reforms” (NBER January 2026): We estimate heterogeneous responses to top-bracket tax reforms using a triple-difference design that exploits variation in tax rate changes and the thresholds at which they apply. This strategy identifies behavioral responses even
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Critiquing AI-Generated Legal Scholarship
My posts on law professors’ using Generative AI to compose law review articles (first one here, second one here) continue to generate interesting responses. Which, of course, is part of my goal: I blog to learn. Today’s addition: Michael L. Smith (Oklahoma Law), “Generative AI and the Purpose of Legal Scholarship” (forthcoming, U. Mass. L.
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Viswanathan Presents “Earmarked Taxes and Redistribution” Today at San Diego
Manoj Viswanathan (UC Law SF) presents Earmarked Taxes and Redistribution at San Diego today as part of its Tax Law Speaker Series.
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ChatGPT Generates a Novel Tax Strategy
Artificial intelligence can now generate tax minimization strategies when fed only the text of tax authorities — without any internal IRS data and without any laborious hand coding of tax code sections.
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The SSRN Top Five New Tax Papers Ranking Is Broken
The SSRN tax download rankings are broken and may never return
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Book of the Week
University of San Diego Law Professor Lisa Ramsey is just out with Trademarks and Free Speech from Cambridge University Press. Her case is that current trademark law is insufficiently sensitive to First Amendment concerns, and she argues passionately for reform. You can sign up to hear her discuss the book virtually on Feb. 3 at
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AI-Generated Legal Scholarship
I ask, and sometimes I receive. In a recent post, I wondered aloud: Could ChatGPT or any of its rivals (in any of their variations, write a publishable work of legal scholarship? What further questions would the answer (yes? no?) raise? Perhaps that’s been done? The asking? The writing? The submitting? The publishing? I now