Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Gamage & Shanske: What States Should Do Now, Part I
David Gamage (Missouri-Columbia; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), Winter Is Coming: What States Should Do Now, Part I, 116 Tax Notes State 297 (May 5, 2025): This Article addresses the unprecedented fiscal challenges facing state governments as federal policy shifts threaten to create a perfect storm of revenue losses and increased service demands.…
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The State Of The Federal Income Tax System: Poor
Michael L. Schler (Cravath, New York), The State of the Federal Income Tax System: Poor, 187 Tax Notes Fed. 1643 (June 2, 2025): In this report, Schler offers a pessimistic view of the state of the federal income tax system, arising from a confluence of factors related to the courts, Congress, and the executive branch.…
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Zelenak: Congress Should Not Make It More Profitable To Donate Than To Sell
Lawrence A. Zelenak (Duke; Google Scholar), Congress: Don’t Make It More Profitable to Donate Than to Sell, 187 Tax Notes Fed. 1443 (May 26, 2025): Zelenak explains how the proposed 100 percent credit for donations to certain organizations would, as drafted, allow donors of appreciated securities to realize a greater after-tax profit than if they…
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The Corporate AMT Raises Little Revenue. Rescore And Repeal It.
Mason Ethington (BYU), Jeffrey L. Hoopes (North Carolina; Google Scholar) & Jacob Thornock (BYU), The Corporate AMT Raises Little Revenue. Rescore and Repeal It., 187 Tax Notes Fed. 1431 (May 26, 2025): In this article, the authors analyze the most recent SEC disclosures from public companies about the corporate alternative minimum tax, finding that few…
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Avi-Yonah & Narotzki: Deglobalization, Tax Competition, And The Potential Revival Of The Welfare State
Reuven S. Avi-Yonah (Michigan; Google Scholar) & Doron Narotzki (Akron; Google Scholar), Deglobalization, Tax Competition, And the Potential Revival Of the Welfare State, 187 Tax Notes Fed. 1041 (May 12, 2025): Deglobalization comes at a cost, but at this point it appears to be a sustained trend. Even if this trajectory changes in the future,…
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Harvard Has Options If It Loses Tax-Exempt Status
Ellen P. Aprill (Loyola-L.A.; Google Scholar), Brian Galle (Georgetown, moving to UC-Berkeley; Google Scholar), Philip Hackney (Pittsburgh; Google Scholar) & Lloyd Hitoshi Mayer (Notre Dame; Google Scholar), Harvard Does Have Options if It Loses Tax-Exempt Status, 187 Tax Notes Fed. 1519 (May 26, 2025): As scholars of nonprofit, tax-exempt organizations, we wish to take issue…
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Passive Income Withholding: $200 Billion In Revenue Without Raising Taxes
Jay A. Soled (Rutgers; Google Scholar) & James Alm (Tulane; Google Scholar), Passive Income Withholding: $200 Billion in Revenue Without Raising Taxes, 187 Tax Notes Fed. 1163 (May 19, 2025): In this article, Soled and Alm propose a reform under which estimated taxes on investment income would, by default, be automatically withheld by the institution…
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Request For Nominations: Tax Analysts Award of Distinction (State & Local Tax)
Request for Nominations: Tax Analysts Award of Distinction Tax Analysts is proud to introduce the Awards of Distinction, a new annual recognition program honoring individuals and organizations whose work has transformed the field of taxation. Each year, the Awards of Distinction will spotlight innovation, impact, and integrity across three categories: U.S. State and Local Taxation…
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Harvard, Yale, And Others May Have Another Litigation Opportunity
Victor Thuronyi (IMF), Harvard, Yale, and Others May Have Another Litigation Opportunity, 187 Tax Notes Fed. 1241 (May 19, 2025): In this article, Thuronyi examines the constitutionality of a proposed exception to the excise tax on university endowments and the difficulties in determining whether an institution is truly “religious.” … Consider … the exception to…
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What Are The Real Tax Risks For Harvard?
Harvey P. Dale (NYU), Daniel J. Hemel (NYU; Google Scholar) & Jill S. Manny (NYU), What Are the Real Tax Risks for Harvard?, 187 Tax Notes Fed. 1447 (May 26, 2025): Although we focus here on Harvard — the principal target of Trump’s revocation threats so far — our analysis has implications for other nonprofit…
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Has The Supreme Court Already Resolved How Loper Bright Applies To Section 7805 Tax Regulations?
Mitchell M. Gans (Hofstra), Has the Supreme Court Already Resolved How Loper Bright Applies to Section 7805 Regulations?, 187 Tax Notes Fed. 1069 (May 12, 2025): In a recent nontax case, the Supreme Court shed some light on a question that has been the subject of much debate in the tax community: whether, in applying Loper Bright, courts should give…
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Tax Notes’ Taxing Issues Webinar: Reimagining The IRS: A Historic Conversation
(Sponsored Post) Tax Notes will present Reimagining the IRS: A Historic Conversation on Wed., May 28. The webinar is free, and CPE credits are available to attendees who meet the requirements. On Wednesday, May 28 from 2 to 4 p.m. ET, Tax Analysts will bring together four former IRS commissioners for a powerful and timely…
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Gamage: Assessing State Business Taxation
David Gamage (Missouri-Columbia; Google Scholar), Beyond Blinders and Boomerangs: Assessing State Business Taxation, 115 Tax Notes St. 753 (Mar. 17, 2025): Karl A. Frieden’s article, “Wearing Blinders in the Debate Over Business’s ‘Fair Share’ of State Taxes” and his subsequent article, “The Boomerang Effect of the Business ‘Fair Share’ Tax Debate,” jointly contend that progressive…
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Tax Notes’ Taxing Issues Webinar: Reimagining The IRS: A Historic Conversation
(Sponsored Post) Tax Notes will present Reimagining the IRS: A Historic Conversation on Wed., May 28. The webinar is free, and CPE credits are available to attendees who meet the requirements. On Wednesday, May 28 from 2 to 4 p.m. ET, Tax Analysts will bring together four former IRS commissioners for a powerful and timely…
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Tax Considerations For The Potential U.S. Annexation Of Greenland
Libin Zhang (Fried Frank, New York), Tax Considerations for the Potential U.S. Annexation of Greenland, 186 Tax Notes Fed. 1843 (Mar. 10, 2025): There have been many proposals over the last 150 years for the United States to acquire Greenland. However, the tax scholarship literature has neglected to focus on the tax consequences of such…
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Taxing Capital Gains At Death At A Rate Higher Than During Life
Steve Rosenthal (Tax Policy Center) & Robert McClelland (Tax Policy Center; Google Scholar), Taxing Capital Gains at Death at a Rate Higher Than During Life, 186 Tax Notes Fed. 2417 (Mar. 31, 2025): In this article, Rosenthal and McClelland examine various proposals to tax unrealized gains, concluding that the best approach is to tax gifts…
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Thuronyi: A Simpler Approach To Taxing Tips
Victor Thuronyi (Former Lead Tax Counsel, IMF), A Simpler Approach to Taxing Tips, 187 Tax Notes Fed. 305 (Apr. 14, 2025): In this article, Thuronyi explains why exempting tips from taxation is problematic, and he proposes a different solution that would relieve tipped workers of the burden of monthly reporting, thus simplifying compliance and reducing…
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Narotzki: Trump’s Tax Policy—Old Policies, Retroactive Rewards
Doron Narotzki (Akron; Google Scholar), Trump’s Tax Policy: Old Policies, Retroactive Rewards, 187 Tax Notes Fed. 309 (April 14, 2025): In this article, Narotzki explores the significant shortfalls in President Trump’s economic policies over the past several months, emphasizing their dependence on historically ineffective strategies. He argues that Trump’s economic proposals are driven more by…
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Gergen & Nguyen: Exchange Funds At The Back End
Mark P. Gergen (UC-Berkeley) & Adam Nguyen (UC-Berkeley), Exchange Funds at the Back End, 187 Tax Notes Fed. 293 (April 14, 2025): In this article, Gergen and Nguyen explore the application of section 731(c) to distributions of publicly traded securities from an exchange fund. The impetus for this article is a phone call one of…
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Tax Notes’ Taxing Issues Webinar: Pillar Two At A Crossroads: U.S. Policy And What Comes Next
(Sponsored post) Tax Notes will present Pillar Two at a Crossroads: U.S. Policy and What Comes Next on Wed., April 23. The webinar is free, and CPE credits are available to attendees who meet the requirements. The future of the OECD’s pillar 2 project and U.S. involvement remains a focal point of international tax discussions.…
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Galler & Soled: Should PTIN Omissions Be Criminalized?
Linda Galler (Hofstra) & Jay A. Soled (Rutgers; Google Scholar), Should PTIN Omissions Be Criminalized?, 186 Tax Notes Fed. 1831 (Mar. 10, 2025): On January 30 Senate Finance Committee Chair Mike Crapo, R-Idaho, and ranking member Ron Wyden, D-Ore., released a discussion draft of bipartisan legislation pertaining to IRS procedure and administration. Several provisions are…
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Applications Are Open For Two ABA Tax Section Fellowships
ABA Tax Section, Tax Analysts Public Service Fellowship: The application for the 2025-2027 Tax Analysts Public Service Fellowship is now open! Completed applications are due May 15, 2025. Send completed applications to taxlserve@americanbar.org. The Tax Analysts Public Service Fellowship was created in response to a need for tax legal assistance for low-income taxpayers, to foster a greater interest in…
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Applications Are Open For Tax Analysts Summer Fellowship
ABA Tax Section, Tax Analysts Summer Fellowship: The application period for the 2025 Tax Analysts Summer Fellowship is now open. Applications are due March 17, 2025. This will be our inaugural class of fellows. Tax Analysts and the Tax Section are excited to launch the fellowship and review submissions. If you are interested in applying,…
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Tax Notes’ Taxing Issues Webinar: Navigating Potential Partnership Changes Under TCJA 2.0
(Sponsored post) Tax Notes will present Navigating Potential Partnership Changes Under TCJA 2.0 on Wed., Feb. 26. The webinar is free, and CPE credits are available to attendees who meet the requirements. Legislative efforts to reform the Tax Cuts and Jobs Act may bring significant changes to partnership taxation. What proposed modifications to subchapter K…
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New Tax Prof Articles In Tax Notes
Richard Schmalbeck (Duke) & Jay A. Soled (Rutgers; Google Scholar), Make the GSTT Exemption Portable Between Spouses, 186 Tax Notes Fed. 311 (Jan. 13, 2025): In this article, Schmalbeck and Soled argue that the generation-skipping transfer tax exemption should be portable between spouses, which would be consistent with other code provisions that treat married couples…