Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Blue J Predicts: Tax Credits That Bond A Partnership
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Bettina Xue Griffin (Senior Legal Research Associate, Blue J Legal), Tax Credits That Bond a Partnership: Revisiting Cross Refined Coal, 176 Tax Notes Fed. 2069 (Sept. 26, 2022): In this article, Alarie and Griffin revisit Cross Refined Coal, a case for
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Blue J Predicts: Tax Credits That Bond A Partnership
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Bettina Xue Griffin (Senior Legal Research Associate, Blue J Legal), Tax Credits That Bond a Partnership: Revisiting Cross Refined Coal, 176 Tax Notes Fed. 2069 (Sept. 26, 2022): In this article, Alarie and Griffin revisit Cross Refined Coal, a case for
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Gamage & Shanske: Phased Mark-To-Market For Billionaire Income Tax Reforms
David Gamage (Indiana; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), Phased Mark-to-Market for Billionaire Income Tax Reforms, 176 Tax Notes Fed. 1875 (Sept. 19, 2022): In this installment of Academic Perspectives on SALT, Gamage and Shanske advocate for phased mark-to-market as a mechanism for reforming the taxation of investment gains of billionaires and megamillionaires.
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Gamage & Shanske: Phased Mark-To-Market For Billionaire Income Tax Reforms
David Gamage (Indiana; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), Phased Mark-to-Market for Billionaire Income Tax Reforms, 176 Tax Notes Fed. 1875 (Sept. 19, 2022): In this installment of Academic Perspectives on SALT, Gamage and Shanske advocate for phased mark-to-market as a mechanism for reforming the taxation of investment gains of billionaires and megamillionaires.
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Mason: A Wrench In The GLOBE’s Diabolical Machinery
Ruth Mason (Virginia; Google Scholar), A Wrench in the GLOBE's Diabolical Machinery, 99 Tax Notes Int'l 1391 (September 19, 2022): In this article, Mason explains how the global anti-base-erosion rules induce cooperation by states, and how the proposal to enact those rules via a directive in the European Union undermines that inducement to cooperate. ConclusionThis
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Mason: A Wrench In The GLOBE’s Diabolical Machinery
Ruth Mason (Virginia; Google Scholar), A Wrench in the GLOBE's Diabolical Machinery, 99 Tax Notes Int'l 1391 (September 19, 2022): In this article, Mason explains how the global anti-base-erosion rules induce cooperation by states, and how the proposal to enact those rules via a directive in the European Union undermines that inducement to cooperate. ConclusionThis
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Sanchirico: Digital Services Taxes This Time Around
Chris William Sanchirico (Penn; Google Scholar), Digital Services Taxes This Time Around, 176 Tax Notes Fed. 2041 (Sept. 26, 2022): The United States currently has an effectively exclusive taxing right on the high-tech foreign profits of its multinationals — a right it leaves largely unexercised. This has been unacceptable to U.S. trading partners for some
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Sanchirico: Digital Services Taxes This Time Around
Chris William Sanchirico (Penn; Google Scholar), Digital Services Taxes This Time Around, 176 Tax Notes Fed. 2041 (Sept. 26, 2022): The United States currently has an effectively exclusive taxing right on the high-tech foreign profits of its multinationals — a right it leaves largely unexercised. This has been unacceptable to U.S. trading partners for some
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McMahon: Taxing Prison Work
Stephanie Hunter McMahon (Cincinnati), Prison Work Is Taxing and Should Be Taxed, 176 Tax Notes Fed. 1585 (Sept. 5, 2022): In this article, McMahon advocates for Congress to enact when possible, and otherwise to push for, an expansion of the social safety net for prison labor on terms consistent with that for non-incarcerated workers, taking
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McMahon: Taxing Prison Work
Stephanie Hunter McMahon (Cincinnati), Prison Work Is Taxing and Should Be Taxed, 176 Tax Notes Fed. 1585 (Sept. 5, 2022): In this article, McMahon advocates for Congress to enact when possible, and otherwise to push for, an expansion of the social safety net for prison labor on terms consistent with that for non-incarcerated workers, taking
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Avi-Yonah: Medtronic II And The Profit-Shifting Problem
Reuven S. Avi-Yonah (Michigan; Google Scholar), Medtronic II and the Profit-Shifting Problem, 176 Tax Notes Fed. 1575 (Sept. 5, 2022): In this article, Avi-Yonah looks at the Tax Court’s recent Medtronic II [v. Commissioner, T.C. Memo. 2022-84 (Aug. 18, 2022)] decision and considers how the new corporate alternative minimum tax may provide a solution to
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Avi-Yonah: Medtronic II And The Profit-Shifting Problem
Reuven S. Avi-Yonah (Michigan; Google Scholar), Medtronic II and the Profit-Shifting Problem, 176 Tax Notes Fed. 1575 (Sept. 5, 2022): In this article, Avi-Yonah looks at the Tax Court’s recent Medtronic II [v. Commissioner, T.C. Memo. 2022-84 (Aug. 18, 2022)] decision and considers how the new corporate alternative minimum tax may provide a solution to
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Blue J: Deducting Legal Expenses In Mylan
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kim Condon (Senior Legal Research Associate, Blue J Legal), Deducting Legal Expenses: Unpacking the IRS's Appeal in Mylan, 176 Tax Notes Fed. 1419 (Aug. 29, 2022): In this article, Alarie and Condon use machine-learning models to evaluate the strength of
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Blue J: Deducting Legal Expenses In Mylan
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kim Condon (Senior Legal Research Associate, Blue J Legal), Deducting Legal Expenses: Unpacking the IRS's Appeal in Mylan, 176 Tax Notes Fed. 1419 (Aug. 29, 2022): In this article, Alarie and Condon use machine-learning models to evaluate the strength of
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Borden: Fixed-Price Put Options Undermine Section 1031 Treatment Of Tenant-in-Common Interests
Bradley T. Borden (Brooklyn; Google Scholar), Fixed-Price Put Options Undermine Section 1031 Treatment of Tenant-in-Common Interests, 175 Tax Notes Fed. 1989 (June 27, 2022): This article provides a detailed analysis of tenancy-in-common arrangements and shows how fixed-price put options to sell such interests undermine the classification of such arrangements as tenancies-in-common for federal income tax
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Borden: Fixed-Price Put Options Undermine Section 1031 Treatment Of Tenant-in-Common Interests
Bradley T. Borden (Brooklyn; Google Scholar), Fixed-Price Put Options Undermine Section 1031 Treatment of Tenant-in-Common Interests, 175 Tax Notes Fed. 1989 (June 27, 2022): This article provides a detailed analysis of tenancy-in-common arrangements and shows how fixed-price put options to sell such interests undermine the classification of such arrangements as tenancies-in-common for federal income tax
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McMahon: Using The Tax System To Ease Some Of The Dobbs Hardship
Stephanie Hunter McMahon (Cincinnati), Using the Tax System to Ease Some of the Dobbs Hardship, 176 Tax Notes Fed. 1105 (Aug. 18, 2022): Through Dobbs, the Supreme Court has ensured that many women throughout this country won’t have access to abortion in their home states. Even before Dobbs, however, many states had extremely limited access to this medical care.
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McMahon: Using The Tax System To Ease Some Of The Dobbs Hardship
Stephanie Hunter McMahon (Cincinnati), Using the Tax System to Ease Some of the Dobbs Hardship, 176 Tax Notes Fed. 1105 (Aug. 18, 2022): Through Dobbs, the Supreme Court has ensured that many women throughout this country won’t have access to abortion in their home states. Even before Dobbs, however, many states had extremely limited access to this medical care.
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Shaheen: Whirlpool — Law Or Policy?
Fadi Shaheen (Rutgers; Google Scholar), Whirlpool: Law or Policy?, 176 Tax Notes Fed. 959 (Aug. 8, 2022): In this article, Shaheen argues that while two U.S. courts reached the desirable policy result in the Whirlpool case [Whirlpool Financial Corp. v. Commissioner, 154 T.C. 142 (2020), aff’d, No. 13986-17 (6th Cir. 2021)], their conclusion that the
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Shaheen: Whirlpool — Law Or Policy?
Fadi Shaheen (Rutgers; Google Scholar), Whirlpool: Law or Policy?, 176 Tax Notes Fed. 959 (Aug. 8, 2022): In this article, Shaheen argues that while two U.S. courts reached the desirable policy result in the Whirlpool case [Whirlpool Financial Corp. v. Commissioner, 154 T.C. 142 (2020), aff’d, No. 13986-17 (6th Cir. 2021)], their conclusion that the
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Avi-Yonah & Wells: Pillar 2 And The Corporate AMT
Reuven Avi-Yonah (Michigan; Google Scholar) & Bret Wells (Houston; Google Scholar), Pillar 2 and the Corporate AMT, 176 Tax Notes Fed. 953 (Aug. 8, 2022): In this article, Avi-Yonah and Wells argue that the corporate alternative minimum tax proposed in the Inflation Reduction Act of 2022 would put the United States in a better position
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Avi-Yonah & Wells: Pillar 2 And The Corporate AMT
Reuven Avi-Yonah (Michigan; Google Scholar) & Bret Wells (Houston; Google Scholar), Pillar 2 and the Corporate AMT, 176 Tax Notes Fed. 953 (Aug. 8, 2022): In this article, Avi-Yonah and Wells argue that the corporate alternative minimum tax proposed in the Inflation Reduction Act of 2022 would put the United States in a better position
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Ordower: Block Rewards, Carried Interests, And Other Valuation Quandaries In Taxing Compensation
Henry Ordower (St. Louis; Google Scholar), Block Rewards, Carried Interests, and Other Valuation Quandaries in Taxing Compensation, 175 Tax Notes Fed. 1551 (June 6, 2022): In this article, Ordower contextualizes block rewards litigation with historical failures to tax compensation income paid in kind. Tax fairness principles demand current taxation of the noneconomically diluting block rewards’
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Ordower: Block Rewards, Carried Interests, And Other Valuation Quandaries In Taxing Compensation
Henry Ordower (St. Louis; Google Scholar), Block Rewards, Carried Interests, and Other Valuation Quandaries in Taxing Compensation, 175 Tax Notes Fed. 1551 (June 6, 2022): In this article, Ordower contextualizes block rewards litigation with historical failures to tax compensation income paid in kind. Tax fairness principles demand current taxation of the noneconomically diluting block rewards’
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Blue J: Accurate Financial Recordkeeping And Business Deductions
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Legal Research Associate, Blue J Legal), Situational Awareness: Accurate Financial Recordkeeping and Business Deductions, 176 Tax Notes Fed. 713 (Aug. 1, 2022): In this article, Alarie and Gardhouse explore the Tax Court decision in Skolnick [v. Commissioner, T.C. Memo.