Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Tax Notes and Shanske on California’s Proposed Billionaire’s Tax
On Friday, Shu-Yi posted about a new Wall Street Journal report on California’s new proposed one-time wealth tax on billionaires. Tax Notes also has a report on the proposal, including some commentary from Darien Shanske (UC Davis law): Darien Shanske, a tax law expert at the University of California, Davis School of Law (King Hall),…
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Tax Notes Student Writing Competition
The submission period is open for the 2026 Tax Notes Student Writing Competition. Submissions are due June 30, 2026. Our annual student writing competition recognizes superior student writing on unsettled questions in tax law or policy. The competition is open to any student enrolled in a law, business, or public policy program during the 2025-2026…
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Kamin: Tax Reform After the One Big Beautiful Bill Act
David Kamin (NYU), Tax Reform After the One Big Beautiful Bill Act, 2025 Tax Notes Today International 213-20 (November 5, 2025) The One Big Beautiful Bill Act (P.L. 119-21) and the tariffs imposed by President Trump have made progressive tax reform all the more urgent, but they have also made any such reform efforts more…
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IRS Watchdog Report: Staff Shortage to Hit Taxpayer Service
Tax Notes has a new article today (“IRS Staff Shortage to Hit Taxpayer Service, IT Work, Watchdog Says“), based on a new report from the Treasury Inspector General For Tax Administration. The full report is here, and here is the intro to the Tax Notes piece: Deep reductions in the IRS workforce will create challenges…
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32nd Annual Hartman State and Local Tax Forum Begins Today
The 32nd Annual Paul J. Hartman Memorial State and Local Tax (SALT) Forum, sponsored in conjunction with the Vanderbilt University Law School, begins today and will run through Wednesday. The Forum commences with a Luncheon & Presentation of the Inaugural Tax Analysts Award of Distinction for Contributions in State and Local Taxation. The full conference agenda,…
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Herzfeld: Rationalizing the Post-OBBBA International Tax Rules
Mindy Herzfeld (Florida), Rationalizing the Post-OBBBA International Tax Rules, 120 Tax Notes Int’l 431 (Oct. 20, 2025) The One Big Beautiful Bill Act (P.L. 119-21) included several important revisions to international tax rules. For the most part, these changes tweaked the law to address concerns about how provisions in the Tax Cuts and Jobs Act operated, or to fix…
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The Supreme Court’s 2024 Term In Tax
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC), The Supreme Court’s 2024 Term in Tax, 188 Tax Notes Fed. 781 (Aug. 4, 2025): In this article, Cummings examines the 2024 term of the Supreme Court, in which it seems to have returned to the norm of rendering a few “boring” tax decisions, although he…
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Facebook Decision Enables IRS To Seek Commensurate With Income Enforcement Against Meta
Stephen L. Curtis (Cross Border Analytics), Reuven S. Avi-Yonah (Michigan; Google Scholar) & David G. Chamberlain (Cal Poly; Google Scholar), Facebook Decision Enables IRS to Seek CWI Enforcement Against Meta, 188 Tax Notes Fed. 709 (Aug. 4, 2025): In this report, the authors explain how the Tax Court’s recent decision in the Facebook transfer pricing case —…
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Aprill: Misunderstanding National Religious Broadcasters
Ellen P. Aprill (Loyola-L.A.; Google Scholar), Misunderstanding National Religious Broadcasters, 188 Tax Notes Fed. 581 (July 28, 2025): This piece examines the proposed order and joint motion for entry of consent judgment in National Religious Broadcasters v. Commissioner addressing the relationship between the Johnson Amendment, which prohibits campaign intervention for any entity exempt under section 501(c)(3),…
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Raskolnikov: A New View Of Formal Equality And A Case For Predistribution
Alex Raskolnikov (Columbia), A New View of Formal Equality and a Case for Predistribution, 17 J. Legal Analysis ___ (2025): A long-held egalitarian view is that formal equality-the absence of formal legal distinctions based on the material resources of individuals-is regressive. If legal rules are the same for the rich and the poor, the rich…
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The Tax Trap Of Israeli Mutual Funds
Ronen Perry (Haifa; Google Scholar), The Tax Trap of Israeli Mutual Funds One of the most troubling phenomena for Israeli retail investors is the tax trap that domestic investment companies regularly set for them. The problem can be described in a nutshell as follows: An investment company establishes a new mutual fund for investment in…
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The Worthlessness Deduction for Partnership Interests: An Unguided Missile
Walter D. Schwidetzky (Baltimore), The Worthlessness Deduction for Partnership Interests: An Unguided Missile, 183 Tax Notes Fed. 461 (Apr. 15, 2024): In this article, I explain how a disjuncture between the provisions governing capital loss treatment and those governing ordinary loss treatment has created tax planning opportunities for a partner taking a worthlessness deduction for…
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Kern: Does The U.S. Exception Threaten Pillar Two?
Adam Kern (San Diego; Google Scholar), Does the U.S. Exception Threaten Pillar Two?, 188 Tax Notes Fed. 387 (July 21, 2025): The G7’s proposal to recognize GILTI as a qualifying IIR [Income Inclusion Rule] is a milestone in the project of establishing a global minimum tax. If accepted, it would establish two minimum tax regimes: one…
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OBBBA: Remittance Tax Goes From Highly Problematic To Barely There
Laura Snyder (Association of Americans Resident Overseas), OBBBA: Remittance Tax Goes From Highly Problematic to Barely There, 188 Tax Notes Fed. 31 (July 7, 2025): The various versions of One Big Beautiful Bill contained a tax on remittance transfers. This article compares the different versions of the tax as it was modified in each version of…
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The Solution To Pope Leo’s Tax Problems
Following up on my previous post, Will Tax Complexity Force Pope Leo To Renounce His U.S. Citizenship?: Libin Zhang (Fried Frank, New York), Papal-American Tax Problems and a Solution, 187 Tax Notes 2093 (June 16, 2025): On May 8 the College of Cardinals elevated the American-born Robert Francis Prevost to be the newest Pope of the…
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Avi-Yonah: Should Congress Reform The Accumulated Earnings Tax?
Reuven Avi-Yonh (Michigan; Google Scholar), Should Congress Reform the Accumulated Earnings Tax?, 187 Tax Notes Fed. 1493 (May 26, 2025): In this installment of Reflections With Reuven Avi-Yonah, Avi-Yonah explains why the shifting landscape of the corporate tax rate requires congressional intervention.
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Regulatory Mismatches In The United States And The European Union
Michael S. Knoll (Penn), Ruth Mason (Virginia; Google Scholar) & Wolfgang Schoen (Max Planck Institute), Regulatory Mismatches in the United States and the European Union(2025) This article explores regulatory mismatches, differences in regulations between different states, in the United States and the European Union, focusing on their differing approaches to market integration and regulatory diversity.…
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The Logic Of The Revenge Tax
Wei Cui (British Columbia; Google Scholar), The Logic of the Revenge Tax, 188 Tax Notes Fed. 37 (July 7, 2025): The United States possesses unique market power as a capital importer and provider of financial services to the rest of the world. It is thus in a strong position to raise revenue from foreign investors and users…
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Zelenak: The Brave New World of Automated Agency Guidance
Lawrence A. Zelenak (Duke; Google Scholar), The Brave New World of Automated Agency Guidance, 187 Tax Notes Fed. 2489 (June 30, 2025) (reviewing Joshua D. Blank (UC-Irvine; Google Scholar) & Leigh Osofsky (North Carolina; Google Scholar), Automated Agencies: The Transformation of Government Guidance (Cambridge University Press 2025): IntroductionIn a 1990 episode of the television sitcom Roseanne,…
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Polsky: Tax Weaponization Via Reconciliation
Gregg D. Polsky (NYU; Google Scholar), Something New Under the Sun: Tax Weaponization via Reconciliation, 187 Tax Notes Fed. 2483 (June 30, 2025): Tucked within the nearly 550 pages of the mammoth Senate Finance Committee’s reconciliation bill is a strange provision that will, if included in the final legislation, effectively destroy an entire industry without…
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Netanya Hosts 9th International Roundtable On Taxation And Tax Policy
Netanya hosts the 9th International Roundtable on Taxation and Tax Policy (program) today: Session I: International Taxation I: Pillar Two Chair: Yoram Margalioth (Tel Aviv University) Sagit Leviner (Ono Academic College; Google Scholar), The Two Pillar Reform in International Taxation of Multinational Corporations: Challenges and Policy Recommendations: The current international tax system, designed over a…
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Johnson: Cut $1 Trillion Of Governmental Fat Out Of Tax Expenditures
Calvin H. Johnson (Texas), Cut $1 Trillion of Governmental Fat Out of Tax Expenditures, 187 Tax Notes Fed. 2247 (June 23, 2025): In this report, Johnson argues that tax expenditures are always wasteful because only a fraction of their cost is passed on to the purported beneficiaries and that direct government dollars could accomplish the…
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Soled & Todd: Hiring Biases Fostered Under The Code
Jay A. Soled (Rutgers; Google Scholar) & Timothy M. Todd (Liberty; Google Scholar), Hiring Biases Fostered Under the Code, 187 Tax Notes Fed. 2273 (June 23, 2025): In this article, Soled and Todd argue that current tax law gives U.S. employers a financial incentive to hire job applicants who have secured certain foreign visa statuses,…
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Avi-Yonah: Should Harvard And Other Large Nonprofits Be Taxed?
Reuven S. Avi-Yonah (Michigan; Google Scholar), Should Harvard and Other Large Nonprofits Be Taxed?, 187 Tax Notes Fed. 2299 (June 23, 2025): In this installment of Reflections With Reuven Avi-Yonah, Avi-Yonah examines justifications for exempting Harvard University and other large nonprofits from tax and argues that treating those organizations like large C corporations would not be such a bad…
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Zelinsky: Private Foundations, DAFs, And The One Big Beautiful Bill Act
Edward A. Zelinsky (Cardozo), Private Foundations, DAFs, and the One Big Beautiful Bill Act, 187 Tax Notes Fed. 2135 (June 16, 2025): In this article, Zelinsky examines the One Big Beautiful Bill Act’s proposed progressive tax rate structure for large private foundations’ net investment income, pointing out that the bill doesn’t apply the same structure…