Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Scholarship
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Schizer & Calabresi: Wealth Taxes Under The Constitution — An Originalist Analysis
David M. Schizer (Columbia) & Steven G. Calabresi (Northwestern), Wealth Taxes Under the Constitution: An Originalist Analysis, 77 Fla. L. Rev. 1401 (2025): A federal wealth tax is high on the wish list of progressives, but is it constitutional? This Article shows that under the original public meaning of the Constitution, a wealth tax is…
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Bloomberg: UK Yields Record £3.4 Billion from Transfer Pricing Cases
Bloomberg, Bloomberg: UK Yields Record £3.4 Billion from Transfer Pricing Cases: The UK’s transfer pricing revenue almost doubled to £3.4 billion ($4.6 billion) in 2024-25 from a year earlier, reaching the highest annual level ever, official data showed Wednesday. Tax revenue raised from settling transfer pricing cases rose from £1.8 billion in 2023-24, as the…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 21 (March 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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The Top 100 Legal Scholars of 2025
Rob Willey (George Mason) & Melanie Knapp (George Mason), The Top 100 Legal Scholars of 2025: Traditional legal scholarship rankings rely almost exclusively on career-long publication metrics, a method that inherently favors decades-old articles and often obscures the authors producing the most impactful research today. This article presents an alternative: a ranking of the 100…
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Goldin & Liscow: When Should the Legal System Help Redistribute Income?
Jacob Goldin (Chicago) & Zachary D. Liscow (Yale), When Should the Legal System Help Redistribute Income?:, 93 U. Chi. L. Rev. 393 (2026): In this Essay, we consider when legal rules should be efficient and when they should not. We focus on conditions that can cause the socially optimal legal rule to diverge from the…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 18 (March 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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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 17 (March 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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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…