Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Avi-Yonah Posts Two International Tax Papers On SSRN
Reuven Avi-Yonah (Michigan; Google Scholar) has posted two international tax papers on SSRN: The First US Tax Treaty and Its Influence: This paper discusses the first US tax treaty concluded with France in 1932 and ratified in 1935. This treaty is interesting because it follows the League of Nations model of 1928 but with significant
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Thorndike: Moores Lean On 1916 Tax Expert To Argue No Realization Means No Income
Joseph J. Thorndike (Tax Analysts), Tax History: Moores Lean on 1916 Tax Expert to Argue No Realization Means No Income, 181 Tax Notes Fed. 1356 (Nov. 20, 2023): Apparently, Charles G. Moore and Kathleen F. Moore are in thrall to a certain Columbia University economist from the early 20th century. Edwin R.A. Seligman is a
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Thorndike: Moores Lean On 1916 Tax Expert To Argue No Realization Means No Income
Joseph J. Thorndike (Tax Analysts), Tax History: Moores Lean on 1916 Tax Expert to Argue No Realization Means No Income, 181 Tax Notes Fed. 1356 (Nov. 20, 2023): Apparently, Charles G. Moore and Kathleen F. Moore are in thrall to a certain Columbia University economist from the early 20th century. Edwin R.A. Seligman is a
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Exclusive Article Submission Window For The Tax Lawyer
The Tax Lawyer is offering an exclusive submission window for articles to be published in the Spring issue of the Tax Lawyer through December 1, 2023. If you’ve got a completed or almost completed draft of an article on any tax issue of 12,000-35,000 words, please submit it to Editor, Publications, at taxweb@americanbar.org. You can
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Exclusive Article Submission Window For The Tax Lawyer
The Tax Lawyer is offering an exclusive submission window for articles to be published in the Spring issue of the Tax Lawyer through December 1, 2023. If you’ve got a completed or almost completed draft of an article on any tax issue of 12,000-35,000 words, please submit it to Editor, Publications, at taxweb@americanbar.org. You can
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Discriminatory Taxes And Congress: Do As I Say, Not As I Do
Laura Snyder (President, Stop Extraterritorial American Taxation (SEAT); Board of Directors, Association of Americans Resident Overseas (AARO)), Discriminatory Taxes and Congress: Do as I Say, Not as I Do, 180 Tax Notes Fed. 1283 (Aug. 21, 2023): For decades, overseas Americans and others have appealed to Congress to act regarding the U.S. extraterritorial tax system.
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Discriminatory Taxes And Congress: Do As I Say, Not As I Do
Laura Snyder (President, Stop Extraterritorial American Taxation (SEAT); Board of Directors, Association of Americans Resident Overseas (AARO)), Discriminatory Taxes and Congress: Do as I Say, Not as I Do, 180 Tax Notes Fed. 1283 (Aug. 21, 2023): For decades, overseas Americans and others have appealed to Congress to act regarding the U.S. extraterritorial tax system.
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Graetz: To Avoid The Moore Morass, The Court Should DIG It (Dismiss As Improvidently Granted)
Michael J. Graetz (Columbia), To Avoid the Moore Morass, the Court Should DIG It — But It Probably Won’t, 181 Tax Notes Fed. 1253 (Nov. 13, 2023): In this article, Graetz examines several of the briefs filed in Moore and argues that regardless of who wins the case, there will be no good outcomes if
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Graetz: To Avoid The Moore Morass, The Court Should DIG It (Dismiss As Improvidently Granted)
Michael J. Graetz (Columbia), To Avoid the Moore Morass, the Court Should DIG It — But It Probably Won’t, 181 Tax Notes Fed. 1253 (Nov. 13, 2023): In this article, Graetz examines several of the briefs filed in Moore and argues that regardless of who wins the case, there will be no good outcomes if
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Blue J: Will AI Replace Tax Practitioners?
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) et al., Will AI Replace Tax Practitioners?, 181 Tax Notes Fed. 855 (Oct. 30, 2023): In the evolving legal landscape created by the advancement of artificial intelligence, we confront a worrying question: Will tax practitioners eventually find themselves sidelined by this technological
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Blue J: Will AI Replace Tax Practitioners?
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) et al., Will AI Replace Tax Practitioners?, 181 Tax Notes Fed. 855 (Oct. 30, 2023): In the evolving legal landscape created by the advancement of artificial intelligence, we confront a worrying question: Will tax practitioners eventually find themselves sidelined by this technological
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Shaheen: 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): In this article, Shaheen 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
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Shaheen: 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): In this article, Shaheen 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
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Borden: Like-Kind Exchange Deadlines That Fall On Weekends And Holidays
Bradley T. Borden (Brooklyn; Google Scholar), Like-Kind Exchange Deadlines That Fall on Weekends and Holidays, 181 Tax Notes Fed. 261 (Oct. 9, 2023): In this article, Borden examines several court decisions that have extended section 7503 deadlines to the next business day, and he argues that the same extension applies to the deadlines under section
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Borden: Like-Kind Exchange Deadlines That Fall On Weekends And Holidays
Bradley T. Borden (Brooklyn; Google Scholar), Like-Kind Exchange Deadlines That Fall on Weekends and Holidays, 181 Tax Notes Fed. 261 (Oct. 9, 2023): In this article, Borden examines several court decisions that have extended section 7503 deadlines to the next business day, and he argues that the same extension applies to the deadlines under section
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Deese & Kamin: Principles For The 2025 Tax Debate
Brian Deese (MIT) & David Kamin (NYU), Principles for the 2025 Tax Debate, 181 Tax Notes Fed. 443 (Oct. 16, 2023): In this article, Deese and Kamin identify core principles for evaluating proposals to address the tax cuts expiring at the end of 2025 and to reform the code more broadly, and they place the
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Deese & Kamin: Principles For The 2025 Tax Debate
Brian Deese (MIT) & David Kamin (NYU), Principles for the 2025 Tax Debate, 181 Tax Notes Fed. 443 (Oct. 16, 2023): In this article, Deese and Kamin identify core principles for evaluating proposals to address the tax cuts expiring at the end of 2025 and to reform the code more broadly, and they place the
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Zelenak: Reading The Taxpayers’ Brief In Moore
Lawrence A. Zelenak (Duke; Google Scholar), Reading the Taxpayers’ Brief in Moore, 181 Tax Notes Fed. 101 (Oct. 2, 2023): In this article, Zelenak explains that the strategy of the taxpayers’ brief in Moore is to distinguish the mandatory repatriation tax from other provisions that arguably violate Eisner v. Macomber, rather than to claim that
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Zelenak: Reading The Taxpayers’ Brief In Moore
Lawrence A. Zelenak (Duke; Google Scholar), Reading the Taxpayers’ Brief in Moore, 181 Tax Notes Fed. 101 (Oct. 2, 2023): In this article, Zelenak explains that the strategy of the taxpayers’ brief in Moore is to distinguish the mandatory repatriation tax from other provisions that arguably violate Eisner v. Macomber, rather than to claim that
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Hellwig: Hoops And The Tax Treatment Of Nonqualified Deferred Compensation Obligations Transferred In The Sale Of Employer’s Assets
Brant J. Hellwig (NYU), Exploring Hoops, 181 Tax Notes Fed. 89 (Oct. 2, 2023): The Seventh Circuit recently issued its opinion in Hoops LP v. Commissioner [77 F.4th 557 (7th Cir. 2023)] concerning the tax treatment of nonqualified deferred compensation obligations that are transferred in connection with the sale of the employer’s assets. The appellate
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Hellwig: Hoops And The Tax Treatment Of Nonqualified Deferred Compensation Obligations Transferred In The Sale Of Employer’s Assets
Brant J. Hellwig (NYU), Exploring Hoops, 181 Tax Notes Fed. 89 (Oct. 2, 2023): The Seventh Circuit recently issued its opinion in Hoops LP v. Commissioner [77 F.4th 557 (7th Cir. 2023)] concerning the tax treatment of nonqualified deferred compensation obligations that are transferred in connection with the sale of the employer’s assets. The appellate
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Rosenthal: Moore Could Invalidate Decades Of Tax Rules
Steven M. Rosenthal (Tax Policy Center), Moore Could Invalidate Decades of Tax Rules, 181 Tax Notes Fed. 285 (Oct. 9, 2023): Former House Speaker Paul Ryan, R-Wis., recently warned that a “lot of the tax code would be unconstitutional” if the Supreme Court rules for the petitioners in Moore. In Moore, U.S. shareholders in a
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Rosenthal: Moore Could Invalidate Decades Of Tax Rules
Steven M. Rosenthal (Tax Policy Center), Moore Could Invalidate Decades of Tax Rules, 181 Tax Notes Fed. 285 (Oct. 9, 2023): Former House Speaker Paul Ryan, R-Wis., recently warned that a “lot of the tax code would be unconstitutional” if the Supreme Court rules for the petitioners in Moore. In Moore, U.S. shareholders in a
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Blue J: Automated Tax Planning — Who’s Liable When AI Gets It Wrong?
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal), et al., Automated Tax Planning: Who’s Liable When AI Gets It Wrong?, 180 Tax Notes Fed. 2297 (Sept. 25, 2023): Considering the continued proliferation of and rapid advancement in artificial intelligence technology, tax professionals are increasingly finding themselves confronted with novel accountability
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Blue J: Automated Tax Planning — Who’s Liable When AI Gets It Wrong?
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal), et al., Automated Tax Planning: Who’s Liable When AI Gets It Wrong?, 180 Tax Notes Fed. 2297 (Sept. 25, 2023): Considering the continued proliferation of and rapid advancement in artificial intelligence technology, tax professionals are increasingly finding themselves confronted with novel accountability