Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Shanske & Gamage: Why States Should Conform To The New Corporate AMT
Darien Shanske (UC-Davis; Google Scholar) & David Gamage (Indiana-Maurer; Google Scholar), Why States Should Conform to the New Corporate AMT, 107 Tax Notes St. 601 (Feb. 13, 2023): This Essay argues that U.S. state governments should conform to the recently enacted federal corporate alternative minimum tax, so as to raise revenues by combatting corporate profits
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Shanske & Gamage: Why States Should Conform To The New Corporate AMT
Darien Shanske (UC-Davis; Google Scholar) & David Gamage (Indiana-Maurer; Google Scholar), Why States Should Conform to the New Corporate AMT, 107 Tax Notes St. 601 (Feb. 13, 2023): This Essay argues that U.S. state governments should conform to the recently enacted federal corporate alternative minimum tax, so as to raise revenues by combatting corporate profits
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Does America Soak The Affluent?
Wall Street Journal Editorial, How America Soaks the Affluent: The Internal Revenue Service recently released its income and tax statistics for 2020, and they show the top 1% of earners paid 42.3% of the country’s income taxes. That’s a two-decade high in the share of taxes the 1% pay. That same 1% reported earnings of
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Does America Soak The Affluent?
Wall Street Journal Editorial, How America Soaks the Affluent: The Internal Revenue Service recently released its income and tax statistics for 2020, and they show the top 1% of earners paid 42.3% of the country’s income taxes. That’s a two-decade high in the share of taxes the 1% pay. That same 1% reported earnings of
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Alm, Soled & Thomas: Revising Form 1040 For The 21st Century
James Alm (Tulane; Google Scholar), Jay A. Soled (Rutgers; Google Scholar) & Kathleen DeLaney Thomas (North Carolina; Google Scholar), Revising Form 1040 for the 21st Century, 178 Tax Notes Fed. 1713 (Mar. 13, 2023): In this article, the authors argue that Form 1040 should be updated to reflect modern technology and social science research by
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Alm, Soled & Thomas: Revising Form 1040 For The 21st Century
James Alm (Tulane; Google Scholar), Jay A. Soled (Rutgers; Google Scholar) & Kathleen DeLaney Thomas (North Carolina; Google Scholar), Revising Form 1040 for the 21st Century, 178 Tax Notes Fed. 1713 (Mar. 13, 2023): In this article, the authors argue that Form 1040 should be updated to reflect modern technology and social science research by
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Curtis & Avi-Yonah: Microsoft’s Cost-Sharing Arrangement — Frankenstein Strikes Again
Stephen L. Curtis (Cross Border Analytics) & Reuven S. Avi-Yonah (Michigan; Google Scholar), Microsoft’s Cost-Sharing Arrangement: Frankenstein Strikes Again, 178 Tax Notes Fed. 1433 (Mar. 6, 2023): In this report, Curtis and Avi-Yonah break down Microsoft’s cost-sharing arrangement and explain how corporate taxpayers have been able to improperly exploit the cost-sharing regulations to shift hundreds of billions or even trillions
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Curtis & Avi-Yonah: Microsoft’s Cost-Sharing Arrangement — Frankenstein Strikes Again
Stephen L. Curtis (Cross Border Analytics) & Reuven S. Avi-Yonah (Michigan; Google Scholar), Microsoft’s Cost-Sharing Arrangement: Frankenstein Strikes Again, 178 Tax Notes Fed. 1433 (Mar. 6, 2023): In this report, Curtis and Avi-Yonah break down Microsoft’s cost-sharing arrangement and explain how corporate taxpayers have been able to improperly exploit the cost-sharing regulations to shift hundreds of billions or even trillions
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Blue J Predicts With 90% Confidence That Taxpayer In Podlucky Would Not Win Innocent Spouse Claim
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal), Susan Massey (Director, Blue J Legal) & Christopher Yan (Senior Legal Research Associate, Blue J Legal), Relief of Innocent Spouses — Not So Podlucky, 178 Tax Notes Fed. 1339 (Feb. 27, 2023): In this article, the authors use the Blue J machine-learning
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Blue J Predicts With 90% Confidence That Taxpayer In Podlucky Would Not Win Innocent Spouse Claim
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal), Susan Massey (Director, Blue J Legal) & Christopher Yan (Senior Legal Research Associate, Blue J Legal), Relief of Innocent Spouses — Not So Podlucky, 178 Tax Notes Fed. 1339 (Feb. 27, 2023): In this article, the authors use the Blue J machine-learning
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Blue J Predicts: The Intersection Between Tax Credits And Trade Or Business
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Christopher Yan (Senior Legal Research Associate, Blue J Legal), The Intersection Between Tax Credits and Trade or Business, 178 Tax Notes Fed. 689 (Jan. 30, 2022): In last month’s installment of Blue J Predicts [The Rise Of The Robotic Tax
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Blue J Predicts: The Intersection Between Tax Credits And Trade Or Business
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Christopher Yan (Senior Legal Research Associate, Blue J Legal), The Intersection Between Tax Credits and Trade or Business, 178 Tax Notes Fed. 689 (Jan. 30, 2022): In last month’s installment of Blue J Predicts [The Rise Of The Robotic Tax
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Gómez: Too Good To Be True—Private Placement Life Insurance Policies
Luís Calderón Gómez (Cardozo; Google Scholar), Too Good to Be True: Private Placement Life Insurance Policies, 178 Tax Notes Fed. 555 (Jan. 23, 2023): In this article, Calderón Gómez examines a tax avoidance scheme involving private placement life insurance policies — large policies that potentially allow wealthy taxpayers to move their traditionally tax-inefficient investments in
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Gómez: Too Good To Be True—Private Placement Life Insurance Policies
Luís Calderón Gómez (Cardozo; Google Scholar), Too Good to Be True: Private Placement Life Insurance Policies, 178 Tax Notes Fed. 555 (Jan. 23, 2023): In this article, Calderón Gómez examines a tax avoidance scheme involving private placement life insurance policies — large policies that potentially allow wealthy taxpayers to move their traditionally tax-inefficient investments in
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Hellerstein & Appleby: The Internet Tax Freedom Act At 25
Walter Hellerstein (Georgia) & Andrew D. Appleby (Stetson; Google Scholar), The Internet Tax Freedom Act at 25, 107 Tax Notes St. 7 (Jan. 2, 2023): In October 1998, Congress enacted the Internet Tax Freedom Act (ITFA), a temporary three-year “moratorium” on the enactment of new state and local “taxes on Internet access” and on “multiple
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Hellerstein & Appleby: The Internet Tax Freedom Act At 25
Walter Hellerstein (Georgia) & Andrew D. Appleby (Stetson; Google Scholar), The Internet Tax Freedom Act at 25, 107 Tax Notes St. 7 (Jan. 2, 2023): In October 1998, Congress enacted the Internet Tax Freedom Act (ITFA), a temporary three-year “moratorium” on the enactment of new state and local “taxes on Internet access” and on “multiple
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Alarie: The Rise Of The Robotic Tax Analyst
Benjamin Alarie (Toronto; Google Scholar; CEO, Blue J Legal), The Rise of the Robotic Tax Analyst, 178 Tax Notes Fed. 57 (Jan. 2, 2023): As a bold taxwriting experiment, this installment of Blue J Predicts has been generated with the help of an AI assistant, OpenAI’s “Generative Pre-Trained Transformer 3” (GPT-3). GPT-3 is a large
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Alarie: The Rise Of The Robotic Tax Analyst
Benjamin Alarie (Toronto; Google Scholar; CEO, Blue J Legal), The Rise of the Robotic Tax Analyst, 178 Tax Notes Fed. 57 (Jan. 2, 2023): As a bold taxwriting experiment, this installment of Blue J Predicts has been generated with the help of an AI assistant, OpenAI’s “Generative Pre-Trained Transformer 3” (GPT-3). GPT-3 is a large
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Christians & Shay: The Consistency Of Pillar 2 UTPR With U.S. Bilateral Tax Treaties
Allison Christians (McGill; Google Scholar) & Stephen E. Shay (Boston College; Google Scholar), The Consistency of Pillar 2 UTPR With U.S. Bilateral Tax Treaties, 178 Tax Notes Fed. 499 (Jan. 23, 2023): In this report, Christians and Shay explain why the pillar 2 undertaxed profits rule would be consistent with U.S. bilateral income tax treaties,
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Christians & Shay: The Consistency Of Pillar 2 UTPR With U.S. Bilateral Tax Treaties
Allison Christians (McGill; Google Scholar) & Stephen E. Shay (Boston College; Google Scholar), The Consistency of Pillar 2 UTPR With U.S. Bilateral Tax Treaties, 178 Tax Notes Fed. 499 (Jan. 23, 2023): In this report, Christians and Shay explain why the pillar 2 undertaxed profits rule would be consistent with U.S. bilateral income tax treaties,
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Soled & Alm: Is A Tax-Motivated Bonanza Of Electric Vehicle Gifts On The Horizon?
Jay A. Soled (Rutgers; Google Scholar) & James Alm (Tulane; Google Scholar), Is a Bonanza of Electric Vehicle Gifts on the Horizon?, 178 Tax Notes Fed. 257 (Jan. 9, 2023): In this article, Soled and Alm argue that some provisions of the Inflation Reduction Act could encourage taxpayers to make automobile-related gifts, not out of
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Soled & Alm: Is A Tax-Motivated Bonanza Of Electric Vehicle Gifts On The Horizon?
Jay A. Soled (Rutgers; Google Scholar) & James Alm (Tulane; Google Scholar), Is a Bonanza of Electric Vehicle Gifts on the Horizon?, 178 Tax Notes Fed. 257 (Jan. 9, 2023): In this article, Soled and Alm argue that some provisions of the Inflation Reduction Act could encourage taxpayers to make automobile-related gifts, not out of
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Blue J Predicts: Conflicting Duties And The Trust Fund Recovery Penalty
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Ann Velez (Senior Legal Research Associate, Blue J Legal), Cashaw: Conflicting Duties and the Trust Fund Recovery Penalty, 177 Tax Notes Fed. 1257 (Nov. 28, 2022): Employers in the U.S. are required to help the federal government in its tax
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Blue J Predicts: Conflicting Duties And The Trust Fund Recovery Penalty
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Ann Velez (Senior Legal Research Associate, Blue J Legal), Cashaw: Conflicting Duties and the Trust Fund Recovery Penalty, 177 Tax Notes Fed. 1257 (Nov. 28, 2022): Employers in the U.S. are required to help the federal government in its tax
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Fleming, Peroni & Shay: Viewing GILTI Tax Rates Through A Tax Expenditure Lens
J. Clifton Fleming Jr. (BYU; Google Scholar), Robert J. Peroni (Texas) & Stephen E. Shay (Boston College; Google Scholar), Viewing the GILTI Tax Rates Through a Tax Expenditure Lens, 177 Tax Notes Fed. 1525 (Dec. 12, 2022): In this article, the authors explain that for U.S. corporations earning foreign-source active business income through controlled foreign