Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Louis Brandeis, Antitrust, And A Functioning Tax System
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC), Louis Brandeis, Antitrust, and a Functioning Tax System, 175 Tax Notes Fed. 241 (Apr. 11, 2022): In this article, Cummings wonders what happened to Justice Louis Brandeis’s approach to deciding federal tax cases and whether it has anything to do with antitrust policy. … Justice Louis
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Louis Brandeis, Antitrust, And A Functioning Tax System
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC), Louis Brandeis, Antitrust, and a Functioning Tax System, 175 Tax Notes Fed. 241 (Apr. 11, 2022): In this article, Cummings wonders what happened to Justice Louis Brandeis’s approach to deciding federal tax cases and whether it has anything to do with antitrust policy. … Justice Louis
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Sanchirico: Should A Global Minimum Tax Be Country-By-Country?
Chris William Sanchirico (Penn; Google Scholar), Should a Global Minimum Tax Be Country-by-Country?, 175 Tax Notes Fed. 549 (Apr. 25, 2022): In this report, Sanchirico questions the consensus view that a country-by-country approach to global minimum tax design is superior to one based on across-country averaging. ConclusionThis report shows in the context of a simple game
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Sanchirico: Should A Global Minimum Tax Be Country-By-Country?
Chris William Sanchirico (Penn; Google Scholar), Should a Global Minimum Tax Be Country-by-Country?, 175 Tax Notes Fed. 549 (Apr. 25, 2022): In this report, Sanchirico questions the consensus view that a country-by-country approach to global minimum tax design is superior to one based on across-country averaging. ConclusionThis report shows in the context of a simple game
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Blue J Predicts With 86% Confidence Debt-Equity Decision In Tribune Media
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Senior Legal Research Associate, Blue J Legal), The Debt-Equity Distinction and Tribune Media, 175 Tax Notes Fed. 593 (Apr. 25, 2022): In this article, Alarie and Gardhouse use the Blue J debt-equity predictor to analyze part of the
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Blue J Predicts With 86% Confidence Debt-Equity Decision In Tribune Media
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Senior Legal Research Associate, Blue J Legal), The Debt-Equity Distinction and Tribune Media, 175 Tax Notes Fed. 593 (Apr. 25, 2022): In this article, Alarie and Gardhouse use the Blue J debt-equity predictor to analyze part of the
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Rosenbloom: The Branch Rule Of Subpart F
H. David Rosenbloom (Caplin & Drysdale; NYU), The Branch Rule: An Unhurried Read of the Statute, 175 Tax Notes Fed. 87 (Apr. 4, 2022): In this article, Rosenbloom considers the language of the branch rule of subpart F and whether it should apply to both sales and manufacturing branches. No one is likely to nominate
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Rosenbloom: The Branch Rule Of Subpart F
H. David Rosenbloom (Caplin & Drysdale; NYU), The Branch Rule: An Unhurried Read of the Statute, 175 Tax Notes Fed. 87 (Apr. 4, 2022): In this article, Rosenbloom considers the language of the branch rule of subpart F and whether it should apply to both sales and manufacturing branches. No one is likely to nominate
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Blue J Predicts With 65%-94% Confidence Federal Circuit’s Step Transaction Decision In GSS Holdings
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Stefanie Di Giandomenico (Senior Legal Research Associate, Blue J Legal), Timing Is Everything: The Step Transaction Doctrine in GSS Holdings, 174 Tax Notes Fed. 1849 (Mar. 28, 2021): In this article, In this article, Alarie and Di Giandomenico examine the recent
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Blue J Predicts With 65%-94% Confidence Federal Circuit’s Step Transaction Decision In GSS Holdings
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Stefanie Di Giandomenico (Senior Legal Research Associate, Blue J Legal), Timing Is Everything: The Step Transaction Doctrine in GSS Holdings, 174 Tax Notes Fed. 1849 (Mar. 28, 2021): In this article, In this article, Alarie and Di Giandomenico examine the recent
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Judge Ketanji Brown Jackson And Tax Cases
Lee A. Sheppard, The Judicial Experience of Circuit Judge Ketanji Brown Jackson, 174 Tax Notes Fed. 1467 (Mar. 14, 2022): [E]mployers know that elite law schools train their graduates to be appellate judges. They don’t train them to be trial lawyers, trial judges, business planners, wealth advisers, or any of the myriad other practical jobs
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Judge Ketanji Brown Jackson And Tax Cases
Lee A. Sheppard, The Judicial Experience of Circuit Judge Ketanji Brown Jackson, 174 Tax Notes Fed. 1467 (Mar. 14, 2022): [E]mployers know that elite law schools train their graduates to be appellate judges. They don’t train them to be trial lawyers, trial judges, business planners, wealth advisers, or any of the myriad other practical jobs
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Avi-Yonah: The U.S. Should Terminate Its Tax Treaty With Russia
Reuven Avi-Yonah (Michigan; Google Scholar), The United States Should Terminate Its Tax Treaty With Russia, 174 Tax Notes Fed. 1561 (Mar. 14, 2022): I read with interest Marty Sullivan’s recent article arguing against terminating the U.S. tax treaty with Russia, and I respectfully disagree. (Martin A. Sullivan, “Should the United States Terminate Its Tax Treaty With
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Avi-Yonah: The U.S. Should Terminate Its Tax Treaty With Russia
Reuven Avi-Yonah (Michigan; Google Scholar), The United States Should Terminate Its Tax Treaty With Russia, 174 Tax Notes Fed. 1561 (Mar. 14, 2022): I read with interest Marty Sullivan’s recent article arguing against terminating the U.S. tax treaty with Russia, and I respectfully disagree. (Martin A. Sullivan, “Should the United States Terminate Its Tax Treaty With
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Wang: Where People Spend Their Child Tax Credit
Binnan Wang (Case Western), Where People Spend Their Child Tax Credit, 173 Tax Notes Fed. 1061 (Nov. 22, 2021): In this report, Wang examines the different ways the automatic child tax credit is being used by various categories of taxpayers, and she explains why the payments have become a penalty for some middle-incometaxpayers.
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Wang: Where People Spend Their Child Tax Credit
Binnan Wang (Case Western), Where People Spend Their Child Tax Credit, 173 Tax Notes Fed. 1061 (Nov. 22, 2021): In this report, Wang examines the different ways the automatic child tax credit is being used by various categories of taxpayers, and she explains why the payments have become a penalty for some middle-incometaxpayers.
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Blue J Predicts With 86%-95% Confidence That 10th Circuit Will Find That Taxpayer In Olsen Was Not Engaged In A 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), Using Machine Learning to Evaluate the Existence of a Trade or Business: Olsen, 174 Tax Notes Fed. 1231 (Feb. 28, 2021): In this article, Alarie and Yan examine how machine learning
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Blue J Predicts With 86%-95% Confidence That 10th Circuit Will Find That Taxpayer In Olsen Was Not Engaged In A 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), Using Machine Learning to Evaluate the Existence of a Trade or Business: Olsen, 174 Tax Notes Fed. 1231 (Feb. 28, 2021): In this article, Alarie and Yan examine how machine learning
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A Financial Analysis Of Disguised Sales Of Partnership Interests
Bradley T. Borden (Brooklyn; Google Scholar), Douglas L. Longhofer (Central Missouri), Martin E. Connor Jr. (Debevoise & Plimpton) & Nastassia Shcherbatsevich (Cravath, Swaine & Moore), A Financial Analysis of Disguised Sales of Partnership Interests, 172 Tax Notes Fed. 381 (July 19, 2021): This article examines the issues that arise in identifying disguised sales of partnership
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A Financial Analysis Of Disguised Sales Of Partnership Interests
Bradley T. Borden (Brooklyn; Google Scholar), Douglas L. Longhofer (Central Missouri), Martin E. Connor Jr. (Debevoise & Plimpton) & Nastassia Shcherbatsevich (Cravath, Swaine & Moore), A Financial Analysis of Disguised Sales of Partnership Interests, 172 Tax Notes Fed. 381 (July 19, 2021): This article examines the issues that arise in identifying disguised sales of partnership
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Simkovic: Did New Deal Liberalism Steer Too Far To The Right?
Michael Simkovic (USC; Google Scholar), Did New Deal Liberalism Steer Too Far to the Right?, 174 Tax Notes Fed. 681 (Jan. 31, 2022) (reviewing A Half-Century With the Internal Revenue Code: The Memoirs of Stanley S. Surrey (Ajay K. Mehrotra (Northwestern; Google Scholar) & Lawrence Zelenak (Duke), eds. 2022): Ajay K. Mehrotra, professor of law
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Simkovic: Did New Deal Liberalism Steer Too Far To The Right?
Michael Simkovic (USC; Google Scholar), Did New Deal Liberalism Steer Too Far to the Right?, 174 Tax Notes Fed. 681 (Jan. 31, 2022) (reviewing A Half-Century With the Internal Revenue Code: The Memoirs of Stanley S. Surrey (Ajay K. Mehrotra (Northwestern; Google Scholar) & Lawrence Zelenak (Duke), eds. 2022): Ajay K. Mehrotra, professor of law
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Blue J: Using Machine Learning To Crack The Tax Code
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Xue Griffin (Senior Legal Research Associate, Blue J Legal), Using Machine Learning to Crack the Tax Code, 174 Tax Notes Fed. 661 (Jan. 31, 2022): In this article, Alarie and Griffin review Blue J’s machine-learning predictions from the past year
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Blue J: Using Machine Learning To Crack The Tax Code
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Xue Griffin (Senior Legal Research Associate, Blue J Legal), Using Machine Learning to Crack the Tax Code, 174 Tax Notes Fed. 661 (Jan. 31, 2022): In this article, Alarie and Griffin review Blue J’s machine-learning predictions from the past year
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Zelinsky: Simplifying Income Tax Reporting For Americans Abroad
Edward A. Zelinsky (Cardozo), Simplifying Income Tax Reporting for Americans Abroad, 174 Tax Notes Fed. 513 (Jan. 24, 2022): In this article, Zelinsky examines the Tax Simplification for Americans Abroad Act (H.R. 6057) and argues that the tax compliance burden for U.S. citizens living abroad can and should be reduced. ConclusionSimplifying the tax reporting obligations