Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Check-the-Box Regulations After Pillar Two
Carol Wang (Joint Committee on Taxation), Check-the-Box Regulations After Pillar Two, 112 Tax Notes Int'l 1501 (Dec. 11, 2023): Since December 1996, domestic and foreign “eligible entities” have been able to elect their tax classification for U.S. federal income purposes. As a result, eligible entities may elect to be a corporation subject to entity-level tax,
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Clarke: The Overlooked Excise Power In Moore
Conor Clarke (Washington University; Google Scholar), Moore: The Overlooked Excise Power, 181 Tax Notes Fed. 1759 (Dec. 4, 2023): Moore v. United States, a constitutional challenge to the mandatory repatriation tax in the Tax Cuts and Jobs Act, has been litigated almost entirely as a case about the scope of the Sixteenth Amendment. I present
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Clarke: The Overlooked Excise Power In Moore
Conor Clarke (Washington University; Google Scholar), Moore: The Overlooked Excise Power, 181 Tax Notes Fed. 1759 (Dec. 4, 2023): Moore v. United States, a constitutional challenge to the mandatory repatriation tax in the Tax Cuts and Jobs Act, has been litigated almost entirely as a case about the scope of the Sixteenth Amendment. I present
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Fox & Liscow: No More Tax-Free Lunch for Billionaires — Closing The Borrowing Loophole
Edward G. Fox (Michigan; Google Scholar) & Zachary Liscow (Yale; Google Scholar), No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole, 182 Tax Notes Fed. 647 (Jan. 22, 2024): In this article, Fox and Liscow propose a tax on billionaires that would apply to borrowing against assets and explain how it could be designed
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Fox & Liscow: No More Tax-Free Lunch for Billionaires — Closing The Borrowing Loophole
Edward G. Fox (Michigan; Google Scholar) & Zachary Liscow (Yale; Google Scholar), No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole, 182 Tax Notes Fed. 647 (Jan. 22, 2024): In this article, Fox and Liscow propose a tax on billionaires that would apply to borrowing against assets and explain how it could be designed
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Applications Are Open For Two ABA Tax Section Fellowships
ABA Tax Section, Tax Analysts Public Service Fellowship: The application for the 2024-2026 Tax Analysts Public Service Fellowship is now available! The Tax Analysts Public Service Fellowship was created in response to a need for tax legal assistance for low-income taxpayers, to foster a greater interest in tax-related public service and to provide seasoned attorneys the opportunity to move
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Applications Are Open For Two ABA Tax Section Fellowships
ABA Tax Section, Tax Analysts Public Service Fellowship: The application for the 2024-2026 Tax Analysts Public Service Fellowship is now available! The Tax Analysts Public Service Fellowship was created in response to a need for tax legal assistance for low-income taxpayers, to foster a greater interest in tax-related public service and to provide seasoned attorneys the opportunity to move
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Avi-Yonah On Moore
Reuven S. Avi-Yonah (Michigan; Google Scholar), What Is the Best Candidate for a Post-Moore Constitutional Challenge?, 182 Tax Notes Fed. 105 (Jan. 1, 2024): In this first installment of Reflections With Reuven Avi-Yonah, Avi-Yonah evaluates potential areas of future constitutionality challenges in the aftermath of Moore. Reuven S. Avi-Yonah (Michigan; Google Scholar), Effects From Moore: Does the
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Avi-Yonah On Moore
Reuven S. Avi-Yonah (Michigan; Google Scholar), What Is the Best Candidate for a Post-Moore Constitutional Challenge?, 182 Tax Notes Fed. 105 (Jan. 1, 2024): In this first installment of Reflections With Reuven Avi-Yonah, Avi-Yonah evaluates potential areas of future constitutionality challenges in the aftermath of Moore. Reuven S. Avi-Yonah (Michigan; Google Scholar), Effects From Moore: Does the
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Avi-Yonah: 2023 Was A Remarkable Year For The IRS In Tax Litigation
Reuven S. Avi-Yonah (Michigan; Google Scholar), Why Did the IRS Win? A Remarkable Year in Tax Litigation (Part 1), 182 Tax Notes Fed. 307 (Jan. 8, 2024): In this installment of Reflections With Reuven Avi-Yonah, part 1 of a two-part series, Avi-Yonah examines the quickly evolving pattern of successful litigation for the IRS, focusing on
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Avi-Yonah: 2023 Was A Remarkable Year For The IRS In Tax Litigation
Reuven S. Avi-Yonah (Michigan; Google Scholar), Why Did the IRS Win? A Remarkable Year in Tax Litigation (Part 1), 182 Tax Notes Fed. 307 (Jan. 8, 2024): In this installment of Reflections With Reuven Avi-Yonah, part 1 of a two-part series, Avi-Yonah examines the quickly evolving pattern of successful litigation for the IRS, focusing on
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Thomas: Improving The Tax System For Independent Contractors With Quarterly 1099s
Kathleen DeLaney Thomas (North Carolina; Google Scholar), Improving the Tax System for Independent Contractors: Quarterly 1099s, 182 Tax Notes 79 (Jan. 1, 2024): In this article, Thomas proposes a new quarterly form sent to independent contractors that would inform them of their quarterly earnings and their obligation to remit estimated taxes on that income, easing the
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Thomas: Improving The Tax System For Independent Contractors With Quarterly 1099s
Kathleen DeLaney Thomas (North Carolina; Google Scholar), Improving the Tax System for Independent Contractors: Quarterly 1099s, 182 Tax Notes 79 (Jan. 1, 2024): In this article, Thomas proposes a new quarterly form sent to independent contractors that would inform them of their quarterly earnings and their obligation to remit estimated taxes on that income, easing the
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Hemel: Tax Regulations And The New Cost-Benefit Analysis
Daniel J. Hemel (NYU; Google Scholar), Tax Regulations and the New Cost-Benefit Analysis, 181 Tax Notes Fed. 1977 (Dec. 11, 2023): The White House Office of Management and Budget released a much-anticipated revision of its guidance to federal agencies regarding regulatory cost-benefit analysis — a document known as Circular A-4 — on November 9, 2023.
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Hemel: Tax Regulations And The New Cost-Benefit Analysis
Daniel J. Hemel (NYU; Google Scholar), Tax Regulations and the New Cost-Benefit Analysis, 181 Tax Notes Fed. 1977 (Dec. 11, 2023): The White House Office of Management and Budget released a much-anticipated revision of its guidance to federal agencies regarding regulatory cost-benefit analysis — a document known as Circular A-4 — on November 9, 2023.
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Tax Notes Federal 2023 Persons Of The Year: Kathleen And Charles Moore
Marie Sapirie, Persons of the Year: The Moores: The Constitution, Realization, and Two Tax Everymen, 181 Tax Notes Fed. 2091 (Dec. 18, 2023): Every tax practitioner and many readers of editorial pages will recognize their names today, but that wasn’t true until recently. For their role as petitioners in the most highly analyzed and anticipated
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Tax Notes Federal 2023 Persons Of The Year: Kathleen And Charles Moore
Marie Sapirie, Persons of the Year: The Moores: The Constitution, Realization, and Two Tax Everymen, 181 Tax Notes Fed. 2091 (Dec. 18, 2023): Every tax practitioner and many readers of editorial pages will recognize their names today, but that wasn’t true until recently. For their role as petitioners in the most highly analyzed and anticipated
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Seven Tax Experts: The Biggest Implications Of Moore
The Biggest Implications of Moore, 181 Tax Notes Fed. 2147 (Dec. 18, 2023): In this installment of the Star Forum, experts answer the following question: What do you see as the biggest implications of Moore, even though we don’t know for sure how the Supreme Court will decide the case? (The authors drafted their initial essays —
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Seven Tax Experts: The Biggest Implications Of Moore
The Biggest Implications of Moore, 181 Tax Notes Fed. 2147 (Dec. 18, 2023): In this installment of the Star Forum, experts answer the following question: What do you see as the biggest implications of Moore, even though we don’t know for sure how the Supreme Court will decide the case? (The authors drafted their initial essays —
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Blue J: AI And The Future Of Tax Avoidance
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal), AI and the Future of Tax Avoidance, 181 Tax Notes Fed. 1809 (Dec. 4, 2023): This essay directly addresses the significant shift artificial intelligence (AI) is bringing to tax avoidance. AI is revolutionizing the field, previously reliant on expert human navigation,
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Blue J: AI And The Future Of Tax Avoidance
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal), AI and the Future of Tax Avoidance, 181 Tax Notes Fed. 1809 (Dec. 4, 2023): This essay directly addresses the significant shift artificial intelligence (AI) is bringing to tax avoidance. AI is revolutionizing the field, previously reliant on expert human navigation,
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Mason: The Advocate General’s Opinion In Apple—Two Steps Forward, One Step Back
Ruth Mason (Virginia; Google Scholar), The Advocate General’s Opinion in Apple: Two Steps Forward, One Step Back, 112 Tax Notes Int'l 1315 (Dec. 4, 2023): In this article, Mason reviews the advocate general opinion in the case against Ireland for granting illegal state aid to Apple. Advocate General Giovanni Pitruzzella urged Europe’s highest court to
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Mason: The Advocate General’s Opinion In Apple—Two Steps Forward, One Step Back
Ruth Mason (Virginia; Google Scholar), The Advocate General’s Opinion in Apple: Two Steps Forward, One Step Back, 112 Tax Notes Int'l 1315 (Dec. 4, 2023): In this article, Mason reviews the advocate general opinion in the case against Ireland for granting illegal state aid to Apple. Advocate General Giovanni Pitruzzella urged Europe’s highest court to
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Shaheen, Avi-Yonah & Kadet: Is The UTPR A 100 Percent Tax On A Deemed Distribution?
Fadi Shaheen (Rutgers; Google Scholar), Is the UTPR a 100 Percent Tax on a Deemed Distribution?, 181 Tax Notes Fed. 481 (Oct. 16, 2023): This article floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by
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Shaheen, Avi-Yonah & Kadet: Is The UTPR A 100 Percent Tax On A Deemed Distribution?
Fadi Shaheen (Rutgers; Google Scholar), Is the UTPR a 100 Percent Tax on a Deemed Distribution?, 181 Tax Notes Fed. 481 (Oct. 16, 2023): This article floats the proposition that from a U.S. tax perspective, the UTPR is the mathematical, conceptual, and legal equivalent of a 100 percent withholding tax on a deemed distribution by