Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
-
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
-
Burke: Transfers Of Zero-Basis Intangibles To A Partnership
Karen C. Burke (Florida), Transfers of Zero-Basis Intangibles to a Partnership, 174 Tax Notes Fed. 25 (Jan. 3, 2022): In this report, Burke examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related
-
Burke: Transfers Of Zero-Basis Intangibles To A Partnership
Karen C. Burke (Florida), Transfers of Zero-Basis Intangibles to a Partnership, 174 Tax Notes Fed. 25 (Jan. 3, 2022): In this report, Burke examines the problem of contributed zero-basis intangibles in light of the IRS’s inadvertent disclosure of a transaction structured by Bristol-Myers Squibb to shift billions of dollars of built-in gain to a related
-
Hellerstein & Appleby: Does The Supreme Court’s Decision In Wayfair Apply Retroactively?
Walter Hellerstein (Georgia) & Andrew D. Appleby (Stetson; Google Scholar), Does the Supreme Court’s Decision in Wayfair Apply Retroactively?, 102 Tax Notes St. 715 (2021): A recent decision of the Oregon Tax Court suggests that it may be premature to dismiss the challenging questions raised by the retroactive application of Wayfair as entirely hypothetical. Accordingly,
-
Hellerstein & Appleby: Does The Supreme Court’s Decision In Wayfair Apply Retroactively?
Walter Hellerstein (Georgia) & Andrew D. Appleby (Stetson; Google Scholar), Does the Supreme Court’s Decision in Wayfair Apply Retroactively?, 102 Tax Notes St. 715 (2021): A recent decision of the Oregon Tax Court suggests that it may be premature to dismiss the challenging questions raised by the retroactive application of Wayfair as entirely hypothetical. Accordingly,
-
Blue J Predicts: Worker Classification In The Gig Economy
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Legal Research Associate, Blue J Legal), Predicting Worker Classification in the Gig Economy, 173 Tax Notes Fed. 1733 (Dec. 20, 2021): In this article, Alarie and Gardhouse examine the classification of workers in the gig economy and use
-
Blue J Predicts: Worker Classification In The Gig Economy
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Legal Research Associate, Blue J Legal), Predicting Worker Classification in the Gig Economy, 173 Tax Notes Fed. 1733 (Dec. 20, 2021): In this article, Alarie and Gardhouse examine the classification of workers in the gig economy and use
-
The Whiteness Of Tax And How To Narrow The Race Gap
Amanda Athanasiou (Tax Notes), The Whiteness of Tax and How to Narrow the Race Gap: Tax is probably not at the top of anyone’s list of the most diverse legal professions, nor should it be. The 2020 U.S. census revealed a more racially diverse population than was measured a decade earlier, with Black or African
-
The Whiteness Of Tax And How To Narrow The Race Gap
Amanda Athanasiou (Tax Notes), The Whiteness of Tax and How to Narrow the Race Gap: Tax is probably not at the top of anyone’s list of the most diverse legal professions, nor should it be. The 2020 U.S. census revealed a more racially diverse population than was measured a decade earlier, with Black or African
-
Viard: Rethinking The State And Local Business Tax Deduction
Alan D. Viard (American Enterprise Institute), Rethinking the State and Local Business Tax Deduction, 173 Tax Notes Fed. 1261 (Nov. 29, 2021): In this article, Viard examines the federal tax deduction for state and local business taxes, and he analyzes reform options that can narrow or eliminate the preferential treatment for some business taxes.
-
Viard: Rethinking The State And Local Business Tax Deduction
Alan D. Viard (American Enterprise Institute), Rethinking the State and Local Business Tax Deduction, 173 Tax Notes Fed. 1261 (Nov. 29, 2021): In this article, Viard examines the federal tax deduction for state and local business taxes, and he analyzes reform options that can narrow or eliminate the preferential treatment for some business taxes.
-
Warren: The Oxford Proposal For A Corporate Cash Flow Tax
Alvin C. Warren Jr. (Harvard), Evaluating the Oxford Proposal for a Corporate Cash Flow Tax, 173 Tax Notes Fed. 1223 (Nov. 29, 2021): In this article, Warren examines the argument of the Oxford International Tax Group that its proposal for a cash flow tax on domestic sales by domestic and foreign corporations is progressive because
-
Warren: The Oxford Proposal For A Corporate Cash Flow Tax
Alvin C. Warren Jr. (Harvard), Evaluating the Oxford Proposal for a Corporate Cash Flow Tax, 173 Tax Notes Fed. 1223 (Nov. 29, 2021): In this article, Warren examines the argument of the Oxford International Tax Group that its proposal for a cash flow tax on domestic sales by domestic and foreign corporations is progressive because
-
Blue J: Taxpayers Face Uphill Battle In Assignment Of Income Cases
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Legal Research Associate, Blue J Legal), Battling Uphill Against the Assignment of Income Doctrine: Ryder, 173 Tax Notes Fed. 1253 (Nov. 29, 2021): In this article, Alarie and Gardhouse examine the Tax Court’s recent decision in Ryder [T.C.
-
Blue J: Taxpayers Face Uphill Battle In Assignment Of Income Cases
Benjamin Alarie (Osler Chair in Business Law, University of Toronto; CEO, Blue J Legal) & Kathrin Gardhouse (Legal Research Associate, Blue J Legal), Battling Uphill Against the Assignment of Income Doctrine: Ryder, 173 Tax Notes Fed. 1253 (Nov. 29, 2021): In this article, Alarie and Gardhouse examine the Tax Court’s recent decision in Ryder [T.C.
-
Johnson: The Wonderful Mark-to-Market Tax
Calvin H. Johnson (Texas), The Wonderful Mark-to-Market Tax, 173 Tax Notes Fed. 1227 (Nov. 29, 2021): Whatever its role in the current U.S. budget decisions, the proposal for mark-to-market taxation is a wonderful idea, so good to be inevitable — at some point. Mark-to-market taxation would tax shareholders on the annual gain from publicly traded
-
Johnson: The Wonderful Mark-to-Market Tax
Calvin H. Johnson (Texas), The Wonderful Mark-to-Market Tax, 173 Tax Notes Fed. 1227 (Nov. 29, 2021): Whatever its role in the current U.S. budget decisions, the proposal for mark-to-market taxation is a wonderful idea, so good to be inevitable — at some point. Mark-to-market taxation would tax shareholders on the annual gain from publicly traded
-
Nuts And Bolts Of the 2021 Advanced, Enhanced Child Tax Credit
Francine J. Lipman (UNLV; Google Scholar) & James E. Williamson (San Diego State), Nuts and Bolts of the 2021 Advanced, Enhanced Child Tax Credit, 173 Tax Notes 319 (Oct. 18, 2021): The enhancements in the child tax credit (CTC) in the American Rescue Plan Act of 2021 (ARPA) signed by President Biden on March 11
-
Nuts And Bolts Of the 2021 Advanced, Enhanced Child Tax Credit
Francine J. Lipman (UNLV; Google Scholar) & James E. Williamson (San Diego State), Nuts and Bolts of the 2021 Advanced, Enhanced Child Tax Credit, 173 Tax Notes 319 (Oct. 18, 2021): The enhancements in the child tax credit (CTC) in the American Rescue Plan Act of 2021 (ARPA) signed by President Biden on March 11
-
Avi-Yonah: A Different Way to Tax Stock Buybacks
Reuven Avi-Yonah (Michigan), A Different Way to Tax Stock Buybacks, 173 Tax Notes Fed. 1107 (Nov. 22, 2021): In this article, Avi-Yonah reviews the Build Back Better Act, which would impose a 1 percent excise tax on corporate stock buybacks. He argues that while the measure is an effective way to raise revenue from high-income
-
Avi-Yonah: A Different Way to Tax Stock Buybacks
Reuven Avi-Yonah (Michigan), A Different Way to Tax Stock Buybacks, 173 Tax Notes Fed. 1107 (Nov. 22, 2021): In this article, Avi-Yonah reviews the Build Back Better Act, which would impose a 1 percent excise tax on corporate stock buybacks. He argues that while the measure is an effective way to raise revenue from high-income
-
Rosenbloom & Shaheen: Toulouse — No Treaty-Based Credit?
H. David Rosenbloom (Caplin & Drysdale; NYU) & Fadi Shaheen (Rutgers; Google Scholar), Toulouse: No Treaty-Based Credit?, 104 Tax Notes Int'l 417 (Oct. 25, 2021): This article maintains that the U.S. Tax Court’s decision in Toulouse [v. Commissioner, 157 T.C. No. 4 (2021)]— that U.S. tax treaties with France and Italy do not provide a
-
Rosenbloom & Shaheen: Toulouse — No Treaty-Based Credit?
H. David Rosenbloom (Caplin & Drysdale; NYU) & Fadi Shaheen (Rutgers; Google Scholar), Toulouse: No Treaty-Based Credit?, 104 Tax Notes Int'l 417 (Oct. 25, 2021): This article maintains that the U.S. Tax Court’s decision in Toulouse [v. Commissioner, 157 T.C. No. 4 (2021)]— that U.S. tax treaties with France and Italy do not provide a
-
Call For Student Tax Papers: 2022 Chris Bergin Award For Excellence In Writing
Christopher E. Bergin Award for Excellence in Writing: The 2022 submission period for the Christopher E. Bergin Award for Excellence in Writing is now open! This annual award recognizes superior student writing on unsettled questions in tax law or policy. Learn more about the competition guidelines: Eligibility: Applicants must be enrolled in an accredited undergraduate or graduate
-
Call For Student Tax Papers: 2022 Chris Bergin Award For Excellence In Writing
Christopher E. Bergin Award for Excellence in Writing: The 2022 submission period for the Christopher E. Bergin Award for Excellence in Writing is now open! This annual award recognizes superior student writing on unsettled questions in tax law or policy. Learn more about the competition guidelines: Eligibility: Applicants must be enrolled in an accredited undergraduate or graduate