Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Johnston: Bermuda Robs Sacramento and Albany — Who Knew?
David Cay Johnston, Bermuda Robs Sacramento and Albany — Who Knew?, 67 State Tax Notes 423 (Feb. 11, 2013): Johnston writes about a report released by the U.S. Public Interest Research Group Education Fund that examines the revenue that is lost by each state to offshore tax havens. All Tax Analysts content is available through
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Johnston: Law and Order: Tax Squad
David Cay Johnston, Law and Order: Tax Squad, 138 Tax Notes 759 (Feb. 11, 2013): Johnston discusses why it is a bad idea to cut dollars from tax enforcement, and he is skeptical that declining numbers of criminal tax prosecutions are the result of increased voluntary compliance. All Tax Analysts content is available through the
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More on the Pepperdine/Tax Analysts Symposium: Tax Advice for the Second Obama Administration
William Hoffman, Globalization Poses New Challenges for Tax Reform, 2013 TNT 15-9 (Jan. 23, 2013): The effects of globalization and international competition on the U.S. economy and the government’s fiscal condition will require any tax reform effort made in the coming months to be much different from past efforts, panelists said January 18 during a
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Pepperdine/Tax Analysts Symposium Wrap-Up: Tax Advice for the Second Obama Administration
Thanks to everyone who participated in Friday's Pepperdine/Tax Analysts Symposium on Tax Advice for the Second Obama Administration. By any measure, it was spectacular success. We smashed attendance records, as Pepperdine had to open two overflow rooms to handle the crowds. Over 600 people have watched the video of the event: Each and every one
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Johnston: The Fiscal Cliff Tax Deal Makes Deficit Worse
David Cay Johnston, Deficits, Schmeficits, 138 Tax Notes 237 (Jan. 14, 2013) Johnston argues that the fiscal cliff compromise will make it harder to solve the United States’ long-term deficit and debt problems. All Tax Analysts content is available through the LexisNexis® services.
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2012 Tax Person of the Year: Tax Policy Center
Person of the Year: Tax Policy Center, 138 Tax Notes 7 (Jan. 7, 2013): The Urban-Brookings Tax Policy Center is the 2012 Tax Notes Person of the Year, for the indelible mark it made on the presidential campaign; nine other contenders for the title round out the feature. Tanara Ashford (Deputy Assistant Attorney General, Tax
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Sullivan: Double Disappointment With the Fiscal Cliff Deal
Martin A. Sullivan (Tax Analysts), Double Disappointment With the Deal, Doc 2013-46 (Jan. 3, 2013): Martin A. Sullivan discusses the downsides of the fiscal cliff compromise. All Tax Analysts content is available through the LexisNexis® services.
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2012 Year in Review: State & Local Taxes
Shonda Humphrey (Tax Analysts), A Year in Review of State and Local Tax Legal Developments, 66 State Tax Notes 991 (Dec. 24, 2012): Well, 2012 is winding down, and what a year it was. … In the state and local tax area, there were some noteworthy legal developments. All Tax Analysts content is available through
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Bartlett: U.S. Taxes and Government Benefits in an International Context
Bruce Bartlett, U.S. Taxes and Government Benefits in an International Context, 137 Tax Notes 1429 (Dec. 24, 2012): Bruce Bartlett reviews new international data on taxes and healthcare spending as a share of GDP in OECD countries and suggests that Americans' antipathy to taxes may be a function of the modest benefits they receive from
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Sullivan: Why the SALT Deduction Is Always Under Attack
Martin A. Sullivan (Tax Analysts), Why the SALT Deduction Is Always Under Attack, 137 Tax Notes 1267 (Dec. 17, 2012): Martin A. Sullivan argues that policymakers shouldn't be so quick to curtail or eliminate the deduction for state and local taxes. [T]he history of the 1986 act can still teach us about the next tax
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Sullivan: Deduction Caps Can Raise Marginal Rates, Cut Economic Growth
Martin A. Sullivan (Tax Analysts), Deduction Caps Can Raise Marginal Rates, Cut Economic Growth, 137 Tax Notes 939 (Nov. 26, 2012): Long-run job creation through tax cutting is a two-step process. The first step is to lower marginal tax rates. Then those lower marginal rates increase taxpayers’ willingness to invest and seek employment. Most of
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Johnson: Tax Reform and the Presidential Election
Calvin H. Johnson (Texas), Tax Reform and the Presidential Election, 137 Tax Notes 676 (Nov. 5, 2012): Johnson describes the tax plan of Republican presidential nominee Mitt Romney as aggressively promising tax cuts for the richest taxpayers. Although Romney promises no increase in the deficit or tax increases for middle-income earners, it is impossible for
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Sullivan: The Employer Healthcare Exclusion’s Role in Tax Reform
Martin A. Sullivan (Tax Analysts), The Employer Healthcare Exclusion's Role in Tax Reform, 137 Tax Notes 462 (Oct. 29, 2012): Martin A. Sullivan discusses how the exclusion for employer-provided health insurance might be affected by proposals for tax reform. All Tax Analysts content is available through the LexisNexis® services.
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Sullivan: How Much Deficit Reduction for a Grand Bargain?
Martin A. Sullivan (Tax Analysts), How Much Deficit Reduction for a Grand Bargain?, 137 Tax Notes 339 (Oct. 22, 2012): Martin A. Sullivan writes about $3.4 trillion of deficit reduction that will be needed over the next 10 years to put the federal budget on a sustainable course. All Tax Analysts content is available through
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Tax Analysts Hosts Conference Today on Taxes and the Poor
Tax Analysts hosts a roundtable discussion today on Taxes and the Poor at the National Press Club in Washington, D.C. today at 9:00 – 11:00 a.m. EST: Christopher E. Bergin (President and Publisher, Tax Analysts) David Brunori (Executive Vice President, Tax Analysts) Scott A. Hodge (President, Tax Foundation) Chuck Marr (Director of Federal Tax Policy,
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Sullivan: The Hypocrisy of Tax Reform
Martin A. Sullivan (Tax Analysts), The Hypocrisy of Tax Reform, 137 Tax Notes 119 (Oct. 8, 2012): Martin A. Sullivan argues that despite their saying that tax reform is needed, lawmakers often let politics muck up the tax code. All Tax Analysts content is available through the LexisNexis® services.
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Christians: Measuring a Fair Share
Allison Christians (McGill), Measuring a Fair Share, 68 Tax Notes Int'l 95 (Oct. 1, 2012): Allison Christians discusses the difficult policy considerations that go into defining what constitutes an individual's fair share when it comes to paying taxes. All Tax Analysts content is available through the LexisNexis® services.
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Jackel: Tax Aggressiveness and Tax Meekness
Monte A. Jackel (Monte A. Jackel Federal Tax Advisory Services, Washington, D.C.), The Aggressive and the Meek, 137 Tax Notes 1365 (Sept. 18, 2012): In this now-monthly column on current tax policy and issues, Jackel examines the state of the tax practice in taking either aggressive or conservative positions on a tax matter. He also
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Solomon: Corporate Inversions: A Symptom of Larger Tax System Problems
Eric Solomon (Ernst & Young, Washington, D.C.), Corporate Inversions: A Symptom of Larger Tax System Problems 67 Tax Notes Int'l 1203 (Sept. 23, 2012): The enactment of § 7874 in 2004 substantially curtailed inversion activity by U.S. corporations. Nevertheless, some U.S. corporations have inverted and other corporations have considered inverting, although recent temporary regulations have
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Johnson: The ‘No Surplusage’ Canon in State and Local Tax Cases
Steve R. Johnson (Florida State), The 'No Surplusage' Canon in State and Local Tax Cases, 65 State Tax Notes 793 (Sept. 17, 2012): Previous installments of this column have examined numerous canons or conventions of statutory interpretation in their application to state and local tax controversies. This installment considers another canon: the precept that courts
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Sullivan: President Romney’s Tax Reform
Martin A. Sullivan (Tax Analysts), President Romney’s Tax Reform, 136 Tax Notes 1365 (Sept. 18, 2012): In economic analysis, Martin A. Sullivan discusses the options available to Mitt Romney if the Republican presidential nominee is determined to propose revenue-neutral tax reform. All Tax Analysts content is available through the LexisNexis® services.
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Sullivan: The Effects of Interest Allocation Rules in a Territorial System
Martin A. Sullivan (Tax Analysts), The Effects of Interest Allocation Rules in a Territorial System, 136 Tax Notes 1098 (Sept. 4, 2012): In economic analysis, Martin A. Sullivan discusses why interest allocations rules are important if the United States moves to a territorial tax system. All Tax Analysts content is available through the LexisNexis® services.
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Cummings: Reorganization Business Purpose
Jasper L. Cummings, Jr. (Alston & Bird, Durham, NC), Reorganization Business Purpose, 136 Tax Notes 1069 (Aug. 27, 2012): In this article, Cummings explains how corporate taxpayers can avoid having to conjure up a business purpose for an acquisitive reorganization, other than the acquisition. All Tax Analysts content is available through the LexisNexis® services.
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State Taxation of Cloud Computing
Timothy P. Noonan (Hodgson Russ, Buffalo), Nuts-and-Bolts Answers on Cloud Computing, 65 State Tax Notes 527 (Aug. 20, 2012): In Noonan's Notes on Tax Practice, Timothy P. Noonan of Hodgson Russ LLP, Buffalo and New York City, discusses various states' guidance on taxation of cloud computing. All Tax Analysts content is available through the LexisNexis®
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Willens: IRS Moves to Curtail Tax-Free Repatriation of Foreign Earnings
Robert Willens (Robert Willens LLC, New York), IRS Moves to Curtail Tax-Free Repatriation of Foreign Earnings, 136 Tax Notes 847 (Aug. 20, 2012): The IRS continues to police schemes that are designed to enable U.S. shareholders of foreign corporations to extract undistributed earnings without U.S. tax consequences. The latest strategy was implemented through an outbound all-cash