Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Hanlon & Hoopes: The Pharmaceutical Industry’s Effective Tax Rates Before And After The TCJA
Michelle Hanlon (MIT; Google Scholar) & Jeffrey L. Hoopes (North Carolina; Google Scholar), The Pharmaceutical Industry: Effective Tax Rates Before and After the TCJA, 185 Tax Notes Fed. 2325 (Dec. 23, 2024): In this report, Hanlon and Hoopes analyze various measures of the effective tax rate for domestic and foreign pharmaceutical companies in the five…
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IRS Chief Counsel Rescinds Job Offers To 3Ls Accepted Into Honors Program
Tax Notes, Federal Hiring Freeze Quickly Hits Prospective IRS Attorneys: Graduate students who accepted offers to work at the IRS Office of Chief Counsel have begun seeing those offers rescinded following the freeze on federal hiring, according to professors. President Trump on January 20 signed an executive order halting all federal hiring and specifying that…
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Soled: The Estate Tax And Its Tacit Push To Be Charitable
Jay Soled (Rutgers; Google Scholar), The Estate Tax and Its Tacit Push to Be Charitable, 185 Tax Notes Fed. 2375 (Dec. 23, 2024): In this article, Soled argues that Congress should maintain the estate tax because it nudges taxpayers to be more charitable than they likely would be without it. Societies have levied estate taxes…
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Tax Treaties Do Not Protect Overseas Americans
Laura Snyder, Karen Alpert & John Richardson, Tax Treaties Do Not Protect Overseas Americans, 185 Tax Notes Fed. 793 (Oct. 28, 2024): We appreciate this opportunity to respond to “Trump Vows to End ‘Double Taxation’ of Overseas Citizens” by Alexander Rifaat. While we have multiple concerns with the opinions expressed by professor Reuven Avi-Yonah in…
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Avi-Yonah On FDII And Domestic Manufacturing Tax Rate
Reuven S. Avi-Yonah (Michigan; Google Scholar), Should FDII Be Abolished in 2025?, 185 Tax Notes Fed. 2209 (Dec. 16, 2024): Avi-Yonah describes the looming international conflicts regarding the U.S. foreign-derived intangible income provision. Reuven S. Avi-Yonah (Michigan; Google Scholar), A Lower Corporate Tax Rate for Domestic Manufacturing?, 185 Tax Notes Fed. 2401 (Dec. 23, 2024):
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Challenging The Johnson Amendment: What SAFE SPACE Gets Right—And Wrong
Benjamin M. Leff (American; Google Scholar), Challenging the Johnson Amendment: What SAFE SPACE Gets Right—and Wrong, 185 Tax Notes Fed. 51 (Oct. 7, 2024): In this article, Leff argues that the IRS’s interpretation of section 501(c)(3)’s prohibition on campaign intervention (the Johnson Amendment) is unconstitutional, as claimed in a recent Tax Court petition, but that…
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Cryptocurrency Public Key Reporting: Using Embedded Technology To Aid Tax Compliance
Haozheng Jiang (J.D. 2026, St. Louis) & Henry Ordower (St. Louis), Cryptocurrency Public Key Reporting: Using Embedded Technology to Aid Tax Compliance, 185 Tax Notes Fed. 2119 (Dec. 16, 2024): This report proposes that U.S. taxpayers report each blockchain public key they control and associate it with their taxpayer identification numbers or with the TINs…
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A Flawed Critique Of Progressive State Tax Policy
Darien Shanske (UC-Davis; Google Scholar), Michael Mazerov (Center on Budget and Policy Priorities), Dan Bucks (Multistate Tax Commission), Peter Enrich (Northeastern) & Carl Davis (Institute on Taxation and Economic Policy), Incidence Is Not Incidental: A First Response to COST's Flawed Critique of the Pursuit of Progressive State Tax Policy, 114 Tax Notes St. 173 (Oct.…
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Tax Notes 2024 Persons Of The Year
Tax Notes Federal Persons of the Year: Dorothy Brown, Champion for Change: Dorothy Brown reflects on her time spent serving as a member of the Treasury Advisory Committee on Racial Equity and the committee’s ultimate success in advocating for Treasury to release regulations on sharing more data with the Census Bureau to help conduct critical…
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Avi-Yonah & Narotzki: The Tariffs Are Coming! The Tariffs Are Coming!
Reuven S. Avi-Yonah (Michigan; Google Scholar) & Doron Narotzki (Akron; Google Scholar), The Tariffs Are Coming! The Tariffs Are Coming!, 185 Tax Notes Fed. 1991 (Dec. 9, 2024): In this installment of Reflections With Reuven Avi-Yonah, Avi-Yonah and Narotzki explain the use of tariffs and, in light of the new administration’s likelihood of maintaining current…
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Hoopes: Should The IRS Regulate Tax Return Preparers?
Jeffrey L. Hoopes (North Carolina; Google Scholar), Should the IRS Regulate Tax Return Preparers?, 185 Tax Notes Fed. 1963 (Dec. 2, 2024): Tax compliance in the United States is costly and cumbersome. It is no surprise that more than half of all U.S. taxpayers believe it necessary to pay a return preparer to help them…
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Wallace & Welton: Luxury, Pigouvian, Sin, Oh My — A Politically Agreeable Carbon Tax
Clinton G. Wallace (South Carolina; Google Scholar) & Shelley Welton (Penn), Luxury, Pigouvian, Sin, Oh My: A Politically Agreeable Carbon Tax, 185 Tax Notes Fed. 1755 (Dec. 2, 2024): Policymakers and commentators mostly treat economic inequality and climate change as distinct and unrelated challenges. In contrast, the public has been taking a less siloed view:…
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Johnson: The Misfocused Excise Tax On Stock Buybacks
Calvin H. Johnson (Texas), The Misfocused Excise Tax on Stock Buybacks, 185 Tax Notes Fed. 1745 (Dec. 2, 2024): In this article, Johnson argues that the Treasury green book proposal to increase the excise tax on stock buybacks to 4 percent would do more harm than good because it would shift distributions from buybacks to unjustly taxed…
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Sheffrin: Realization Makes An Intellectual Comeback
Steven M. Sheffrin (Tulane; Google Scholar), Realization Makes an Intellectual Comeback, 185 Tax Notes Fed. 1737 (Dec. 2, 2024): The case for taxing unrealized capital gains is based on the Haig-Simons definition of income. In this definition, income equals consumption plus savings when savings includes both realized and unrealized capital gains. If asset prices change…
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Johnson: The ‘Satisfactory Explanation’ Obligation For Tax Regulations
Calvin H. Johnson (Texas), The ‘Satisfactory Explanation’ Obligation for Tax Regulations, 184 Tax Notes Fed. 2713 (Sept. 30, 2024): In this article, Johnson argues that courts should determine whether agencies have provided the required “satisfactory explanation” for new regulations by examining the full internal administrative record of agency deliberations, including agency testimony and not just…
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Original Sin: Cost Sharing In The United States
Elizabeth J. Stevens (Caplin & Drysdale, Washington, D.C.) & H. David Rosenbloom (Caplin & Drysdale, Washington, D.C.; NYU), Original Sin: Cost Sharing in the United States, 185 Tax Notes Fed. 1197 (Nov. 11, 2024): This article explores a simple thesis: that the “cost sharing” rules of the United States are at the core of most…
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Haneman: The Estate Tax And De/Valuing Postmortem Publicity Rights
Victoria J. Haneman (Creighton; Google Scholar), The Estate Tax and De/Valuing Postmortem Publicity Rights, 185 Tax Notes Fed. 1241 (Nov. 11, 2024): Important policy considerations stand in tension at the intersection of tax law and the right to privacy. On the one hand, it is problematic to allow a taxpayer to destroy a valuable asset…
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Rotten To The Core: The EU’s Court Of Justice Decision In Apple
Ruth Mason (Virginia; Google Scholar) & Stephen Daly (King's College London; Google Scholar), Rotten to the Core: The EU's Court of Justice Decision in Apple, 116 Tax Notes Int’l 987 (Nov. 11, 2024): This article takes an in-depth look at the deeply flawed EU Court of Justice decision in the Apple state aid case. We…
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Tax Notes’ Taxing Issues Webinar: Election Implications For Tax Policy
(Sponsored post) Tax Notes will present What's Next for Tax Policy on November 20. The event is both in-person and virtual. The webinar is free, and CPE credits are available to attendees who meet the requirements. This event will feature a postelection reaction panel, delivering cutting-edge analysis and fresh perspectives. Panelists will explore how shifts…
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Shanske: Loper Bright, (Increased?) State Capacity, And (Perhaps?) Pyrrhic Taxpayer Victories
Darien Shanske (UC-Davis; Google Scholar), Loper Bright, (Increased?) State Capacity, and (Perhaps?) Pyrrhic Taxpayer Victories, 113 Tax Notes St. 355 (Aug. 5, 2024): This short essay is a first consideration of how Loper Bright might impact state tax administration. It argues that the indirect impact might be significant if, for example, states with income taxes…
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Schwidetzky: Reforming Self-Employment Taxes
Walter D. Schwidetzky (Baltimore), Reforming Self-Employment Taxes, 185 Tax Notes Fed. 461 (Oct. 21, 2024): In this report, Schwidetzky proposes reforms to address tax avoidance and other problems with self-employment tax. IntroductionTaxpayers for decades have been seeking ways to avoid self-employment taxes. By self-employment taxes, I mean the taxes imposed by section 1401, which are…
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Mazur & Thimmesch: Transforming Tax Communications With Large Language Models
Orly Mazur (SMU; Google Scholar) & Adam Thimmesch (Nebraska; Google Scholar), Transforming Tax Communications With Large Language Models, 185 Tax Notes Fed. 757 (Oct. 28, 2024): In this installment of Academic Perspectives on SALT, Mazur and Thimmesch explore how to improve the efficiency and equity of tax administration through the strategic use of large language…
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Zelenak: Why Nix Tip Tax Now?
Lawrence A. Zelenak (Duke; Google Scholar), Why Nix Tip Tax Now?, 185 Tax Notes Fed. 237 (Oct. 14, 2024): In this article, Zelenak explores why — more than 100 years after a Treasury regulation declared tips taxable — proposals to exempt tips from federal income tax are only now politically viable, and he examines the…
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2024 Tax Notes Student Writing Competition Winner: Nicholas Lott (BYU)
Nicholas Lott (J.D. & MAcc 2025, BYU), New York, Amazon, and Company-Specific Tax Incentives: A Microcosm of a National Problem, 184 Tax Notes Fed. 2525 (Sept. 23, 2024): In this article, Lott centers on the polarizing company-specific tax incentive that New York offered Amazon to entice it to construct its second headquarters in Long Island…
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Fleming, Peroni & Shay: The U.S. Tax System’s Curious Embrace Of Manufacturing Job Losses
J. Clifton Fleming Jr. (BYU; Google Scholar), Robert J. Peroni (Texas) & Stephen E. Shay (Boston College; Google Scholar), The U.S. Tax System’s Curious Embrace of Manufacturing Job Losses, 185 Tax Notes Fed. 35 (Oct. 7, 2024): In this article, the authors explain how the subpart F regime and the global intangible low-taxed income regime together contribute to…