Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Zelinsky: Expand The Taxation Of Educational And Other Charitable Endowments
Edward A. Zelinsky (Cardozo), Expand the Taxation of Educational and Other Charitable Endowments, 173 Tax Notes Fed. 799 (Nov. 8, 2021): In this article, Zelinsky argues that section 4968, which imposes an annual tax on the investment income of some college and university endowments, should remain in the tax code as a revenue measure and
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Zelinsky: Expand The Taxation Of Educational And Other Charitable Endowments
Edward A. Zelinsky (Cardozo), Expand the Taxation of Educational and Other Charitable Endowments, 173 Tax Notes Fed. 799 (Nov. 8, 2021): In this article, Zelinsky argues that section 4968, which imposes an annual tax on the investment income of some college and university endowments, should remain in the tax code as a revenue measure and
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Avi-Yonah: The Case For Reviving The Corporate AMT
Reuven Avi-Yonah (Michigan), The Case for Reviving the Corporate AMT, 173 Tax Notes Fed. 795 (Nov. 8, 2021): In this article, Avi-Yonah examines the bill introduced by Senate Finance Committee member Elizabeth Warren, D-Mass., to revive the corporate alternative minimum tax as a 15 percent tax on corporate book income, and he argues that it
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Avi-Yonah: The Case For Reviving The Corporate AMT
Reuven Avi-Yonah (Michigan), The Case for Reviving the Corporate AMT, 173 Tax Notes Fed. 795 (Nov. 8, 2021): In this article, Avi-Yonah examines the bill introduced by Senate Finance Committee member Elizabeth Warren, D-Mass., to revive the corporate alternative minimum tax as a 15 percent tax on corporate book income, and he argues that it
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Shaviro: Bittker’s Pendulum And The Taxation of Multinationals
Daniel N. Shaviro (NYU), Bittker’s Pendulum and the Taxation of Multinationals, 173 Tax Notes Fed. 621 (Nov. 1, 2021): In this report, Shaviro examines the recent calls for increased entity-level corporate income taxation of multinationals, on both a source and a residence basis, and he details historical parallels.
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Shaviro: Bittker’s Pendulum And The Taxation of Multinationals
Daniel N. Shaviro (NYU), Bittker’s Pendulum and the Taxation of Multinationals, 173 Tax Notes Fed. 621 (Nov. 1, 2021): In this report, Shaviro examines the recent calls for increased entity-level corporate income taxation of multinationals, on both a source and a residence basis, and he details historical parallels.
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Zelinsky: The Case For Limiting The Estate And Gift Tax Charitable Deductions
Edward A. Zelinsky (Cardozo), The Case for Limiting the Estate and Gift Tax Charitable Deductions, 173 Tax Notes Fed. 667 (Nov. 1, 2021): In this article, Zelinsky argues that all large estates should support the federal treasury and that Congress should limit the estate and gift tax charitable deductions to ensure that they pay some
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Zelinsky: The Case For Limiting The Estate And Gift Tax Charitable Deductions
Edward A. Zelinsky (Cardozo), The Case for Limiting the Estate and Gift Tax Charitable Deductions, 173 Tax Notes Fed. 667 (Nov. 1, 2021): In this article, Zelinsky argues that all large estates should support the federal treasury and that Congress should limit the estate and gift tax charitable deductions to ensure that they pay some
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Johnson: The Shelf Project — 82 Fair And Efficient Suggestions To Raise $3.5 Trillion
Calvin H. Johnson (Texas), The Shelf Project: 82 Fair and Efficient Suggestions to Raise $3.5 Trillion, 173 Tax Notes Fed. 63 (Oct. 4, 2021): In this article, Johnson examines Shelf Project proposals that could raise $3.5 trillion in revenue over 10 years without increasing tax rates or the tax burden on lowor middle-income taxpayers while
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Johnson: The Shelf Project — 82 Fair And Efficient Suggestions To Raise $3.5 Trillion
Calvin H. Johnson (Texas), The Shelf Project: 82 Fair and Efficient Suggestions to Raise $3.5 Trillion, 173 Tax Notes Fed. 63 (Oct. 4, 2021): In this article, Johnson examines Shelf Project proposals that could raise $3.5 trillion in revenue over 10 years without increasing tax rates or the tax burden on lowor middle-income taxpayers while
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Hasen: Three Cheers For Proposed Changes To Partnership Debt Basis Allocation Rules
David Hasen (Florida), Three Cheers for Proposed Changes to Partnership Debt Basis Allocation Rules, 173 Tax Notes Fed. 489 (Oct. 25, 2021): In this article, Hasen explains problems with the rules regarding the allocation of basis credit among partners for the partnership’s third-party debt, and why the proposed change from Senate Finance Committee Chair Ron
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Hasen: Three Cheers For Proposed Changes To Partnership Debt Basis Allocation Rules
David Hasen (Florida), Three Cheers for Proposed Changes to Partnership Debt Basis Allocation Rules, 173 Tax Notes Fed. 489 (Oct. 25, 2021): In this article, Hasen explains problems with the rules regarding the allocation of basis credit among partners for the partnership’s third-party debt, and why the proposed change from Senate Finance Committee Chair Ron
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Blue J Predicts With 74% Confidence That 8th Circuit Will Find Customary/Usual Management Fees Are Deductible Under § 162
Benjamin Alarie & Christopher Yan (Blue J Legal), Would Management Fees by Any Other Name Still Be Deductible?, 173 Tax Notes Fed. 499 (Oct. 25, 2021): In this article, Alarie and Yan examine Aspro [T.C. Memo. 2021-8 (Jan. 21, 2021)] and use machine-learning models to evaluate the strength of the appellant’s arguments in its appeal
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Blue J Predicts With 74% Confidence That 8th Circuit Will Find Customary/Usual Management Fees Are Deductible Under § 162
Benjamin Alarie & Christopher Yan (Blue J Legal), Would Management Fees by Any Other Name Still Be Deductible?, 173 Tax Notes Fed. 499 (Oct. 25, 2021): In this article, Alarie and Yan examine Aspro [T.C. Memo. 2021-8 (Jan. 21, 2021)] and use machine-learning models to evaluate the strength of the appellant’s arguments in its appeal
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Beller: S Corporations As Shareholders, LLC Members, And Partners
Herbert N. Beller (Professor of Practice, Northwestern; Of Counsel, Eversheds-Sutherland), S Corporations as Shareholders, LLC Members, and Partners, Part 1, 172 Tax Notes Fed. 1713 (Sept. 13, 2021); S Corporations as Shareholders, LLC Members, and Partners, Part 2, 172 Tax Notes Fed. 1915 (Sept. 20, 2021): This two-part article focuses on numerous transactional scenarios involving
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Beller: S Corporations As Shareholders, LLC Members, And Partners
Herbert N. Beller (Professor of Practice, Northwestern; Of Counsel, Eversheds-Sutherland), S Corporations as Shareholders, LLC Members, and Partners, Part 1, 172 Tax Notes Fed. 1713 (Sept. 13, 2021); S Corporations as Shareholders, LLC Members, and Partners, Part 2, 172 Tax Notes Fed. 1915 (Sept. 20, 2021): This two-part article focuses on numerous transactional scenarios involving
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Accounting Firms Are Beating Law Firms In The Tax Services Battle
Danielle Higgins Green (Fordham), & Stanley Veliotis (Fordham; Google Scholar), Law vs. Accounting Firms: Competing Over Three Decades of Change, 173 Tax Notes Fed. 13 (Oct. 4, 2021): In this report, Green and Veliotis investigate how major regulatory and legislative changes over the past three decades have affected the competitive market for tax services between
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Accounting Firms Are Beating Law Firms In The Tax Services Battle
Danielle Higgins Green (Fordham), & Stanley Veliotis (Fordham; Google Scholar), Law vs. Accounting Firms: Competing Over Three Decades of Change, 173 Tax Notes Fed. 13 (Oct. 4, 2021): In this report, Green and Veliotis investigate how major regulatory and legislative changes over the past three decades have affected the competitive market for tax services between
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Blue J Predicted With 95% Confidence That 7th Circuit Would Affirm Tax Court In Innocent Spouse Cases
Benjamin Alarie & Stefanie Di Giandomenico (Blue J Legal), Seventh Circuit Affirms Spouse Is Not So Innocent on Appeal, 172 Tax Notes Fed. 2149 (Sept. 27, 2021): Clients often ask tax practitioners what their prospects of success are in litigation. Although the practitioner may have an opinion on the issue, the chances of success are often
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Blue J Predicted With 95% Confidence That 7th Circuit Would Affirm Tax Court In Innocent Spouse Cases
Benjamin Alarie & Stefanie Di Giandomenico (Blue J Legal), Seventh Circuit Affirms Spouse Is Not So Innocent on Appeal, 172 Tax Notes Fed. 2149 (Sept. 27, 2021): Clients often ask tax practitioners what their prospects of success are in litigation. Although the practitioner may have an opinion on the issue, the chances of success are often
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Tax Profs Remember Christine Brunswick
Tax Notes has reprinted our tribute in Tax Professors Remember Christine Ann Brunswick, 138 Tax Notes 1267 (Mar. 11, 2013): Paul L. Caron … shares the tributes posted by tax professors remembering Christine Ann Brunswick, former director of the American Bar Association Section of Taxation, who died last month: Alice Abreu (Temple) Ellen Aprill (Loyola-L.A.) Paul
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2003-2012 Tax Journal Rankings: NYU #1, Tax Notes #2
Here are the Washington & Lee tax law review combined rankings of the five major tax journals: Florida Tax Review ("Florida") Tax Law Review ("NYU") Tax Lawyer ("ABA") Tax Notes Virginia Tax Review ("Virginia") The rankings are based on the annual combined rankings in 2003-2012 among these five journals:by: Impact Factor (citations/number of articles published)
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Johnston: Income Inequality: 1 Inch to 5 Miles
David Cay Johnston (Syracuse), Income Inequality: 1 Inch to 5 Miles, 138 Tax Notes 1007 (Feb. 25, 2013): The average increase in real income reported by the bottom 90% of earners in 2011, compared with 1996, if measured at one inch, would extend almost five miles for the top 1% of the top 1%. All
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Tax Analysts Hosts Conference Today on The Federal Income Tax: Has It Run its Course?
Tax Analysts hosts a roundtable discussion on The Federal Income Tax: Has It Run its Course? at the National Press Club in Washington, D.C. today at 9:00 – 11:00 a.m. EST: Please join us for a roundtable discussion on whether the federal income tax, which celebrates its 100th birthday this year, can retain its role
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Sullivan: Can States Swap Sales Taxes for Income Taxes?
Martin A. Sullivan (Tax Analysts), Can States Swap Sales Taxes for Income Taxes?, 138 Tax Notes 789 (Feb. 19, 2013): Among the 44 states with significant income tax revenue, only a few could repeal their income taxes, replace the lost revenue with sales taxes, and keep sales tax rates below 8% with their current sales