Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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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
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Challenging The Johnson Amendment: What SAFE SPACE Gets Right — And Wrong
Benjamin 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
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Challenging The Johnson Amendment: What SAFE SPACE Gets Right — And Wrong
Benjamin 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
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Kamin: The Macroeconomic Context For A 2025 Tax Deal
David Kamin (NYU), The Macroeconomic Context for a 2025 Tax Deal, 184 Tax Notes 2673 (Sept. 30, 2024): In this article, Kamin argues that 2025 looks like a year in which fiscal consolidation would be appropriate given the macroeconomic context for the expiring provisions of the Tax Cuts and Jobs Act, and he explains that
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Kamin: The Macroeconomic Context For A 2025 Tax Deal
David Kamin (NYU), The Macroeconomic Context for a 2025 Tax Deal, 184 Tax Notes 2673 (Sept. 30, 2024): In this article, Kamin argues that 2025 looks like a year in which fiscal consolidation would be appropriate given the macroeconomic context for the expiring provisions of the Tax Cuts and Jobs Act, and he explains that
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Harpaz: Can U.N. Framework Tax Convention Bridge The North-South Divide?
Assaf Harpaz (Georgia; Google Scholar), The U.N. Framework Tax Convention: Can It Bridge the North-South Divide?, 115 Tax Notes Int’l 1779 (Sept. 16, 2024): The United Nations recently concluded the second session of negotiations on terms of reference for a framework convention on international tax cooperation. The framework convention presents an opportunity to multilaterally address
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Harpaz: Can U.N. Framework Tax Convention Bridge The North-South Divide?
Assaf Harpaz (Georgia; Google Scholar), The U.N. Framework Tax Convention: Can It Bridge the North-South Divide?, 115 Tax Notes Int’l 1779 (Sept. 16, 2024): The United Nations recently concluded the second session of negotiations on terms of reference for a framework convention on international tax cooperation. The framework convention presents an opportunity to multilaterally address
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State Conformity To GILTI Is A Good Idea (A Defense of Minnesota)
Peter D. Enrich (Northeastern), Michael Mazerov (Center on Budget and Policy Priorities), Darien Shanske (UC-Davis; Google Scholar) & Dan Bucks (Public Revenues Consulting), State Conformity to GILTI is a Good Idea (A Defense of Minnesota), 110 Tax Notes St. 287 (Oct. 23, 2023): SALT in the Public Interest presents government and academic perspectives on state
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State Conformity To GILTI Is A Good Idea (A Defense of Minnesota)
Peter D. Enrich (Northeastern), Michael Mazerov (Center on Budget and Policy Priorities), Darien Shanske (UC-Davis; Google Scholar) & Dan Bucks (Public Revenues Consulting), State Conformity to GILTI is a Good Idea (A Defense of Minnesota), 110 Tax Notes St. 287 (Oct. 23, 2023): SALT in the Public Interest presents government and academic perspectives on state
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UF Tax Incubator: Complexities, Discontinuities, And Unintended Consequences Of U.S. International Tax Rules
UF Tax Incubator: Complexities, Discontinuities, and Unintended Consequences of US International Tax Rules: Options for Change (American Enterprise Institute Symposium (June 17-18, 2024): Forward (p. 1) Potential Changes to Section 367 and the Associated Treasury Regulations (p. 11) Considerations for Reforming the U.S. Source of Income Rules (p. 27) U.S. Subsidiaries of Foreign-Based MNEs —
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UF Tax Incubator: Complexities, Discontinuities, And Unintended Consequences Of U.S. International Tax Rules
UF Tax Incubator: Complexities, Discontinuities, and Unintended Consequences of US International Tax Rules: Options for Change (American Enterprise Institute Symposium (June 17-18, 2024): Forward (p. 1) Potential Changes to Section 367 and the Associated Treasury Regulations (p. 11) Considerations for Reforming the U.S. Source of Income Rules (p. 27) U.S. Subsidiaries of Foreign-Based MNEs —
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Tax Notes’ Taxing Issues Webinar: TCJA’s Expiration: Navigating The SALT Cap Debate
(Sponsored post) Tax Notes will present TCJA’s Expiration: Navigating the SALT Cap Debate on September 26. The webinar is free and CPE credits are available to attendees who meet the requirements. The expiration of key provisions of the Tax Cuts and Jobs Act will have implications beyond federal tax policy, particularly on the debate around
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Tax Notes’ Taxing Issues Webinar: TCJA’s Expiration: Navigating The SALT Cap Debate
(Sponsored post) Tax Notes will present TCJA’s Expiration: Navigating the SALT Cap Debate on September 26. The webinar is free and CPE credits are available to attendees who meet the requirements. The expiration of key provisions of the Tax Cuts and Jobs Act will have implications beyond federal tax policy, particularly on the debate around
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Thomas: Here’s How Harris’s Standard Business Deduction Could Work
Kathleen DeLaney Thomas (North Carolina; Google Scholar), Here’s How Harris’s Standard Business Deduction Could Work, 184 Tax Notes Fed. 2521 (Sept. 23, 2024): In this article, Thomas explains how Vice President Kamala Harris’s proposed standard deduction for small businesses could be implemented, emphasizing that it would simplify tax filing for qualifying businesses. [A] standard business deduction
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Thomas: Here’s How Harris’s Standard Business Deduction Could Work
Kathleen DeLaney Thomas (North Carolina; Google Scholar), Here’s How Harris’s Standard Business Deduction Could Work, 184 Tax Notes Fed. 2521 (Sept. 23, 2024): In this article, Thomas explains how Vice President Kamala Harris’s proposed standard deduction for small businesses could be implemented, emphasizing that it would simplify tax filing for qualifying businesses. [A] standard business deduction
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Does The End Of Chevron Deference Mean A Weaker IRS?
Mitchell M. Gans (Hofstra), Does the End of Chevron Deference Mean a Weaker IRS?, 184 Tax Notes Fed. 1503 (Aug. 19, 2024): The IRS was a powerful adversary when agencies enjoyed deference. Armed with Chevron deference, the IRS could resolve ambiguity in a code section by regulation. The courts deferred to that regulation — giving it
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Does The End Of Chevron Deference Mean A Weaker IRS?
Mitchell M. Gans (Hofstra), Does the End of Chevron Deference Mean a Weaker IRS?, 184 Tax Notes Fed. 1503 (Aug. 19, 2024): The IRS was a powerful adversary when agencies enjoyed deference. Armed with Chevron deference, the IRS could resolve ambiguity in a code section by regulation. The courts deferred to that regulation — giving it
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The Moores Lost Their Claim And Moore
Lily Batchelder (NYU), Ari Glogower (Northwestern; Google Scholar), Chye-Ching Huang (NYU), David Kamin (NYU), Rebecca Kysar (Fordham; Google Scholar), Kelsey Merrick (NYU), Darien Shanske (UC-Davis; Google Scholar) & Thalia Spinrad (NYU), The Moores Lost Their Claim and Moore, 184 Tax Notes Fed. 1509 (Aug. 19, 2024): In this article, the authors analyze the logic of Moore and
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The Moores Lost Their Claim And Moore
Lily Batchelder (NYU), Ari Glogower (Northwestern; Google Scholar), Chye-Ching Huang (NYU), David Kamin (NYU), Rebecca Kysar (Fordham; Google Scholar), Kelsey Merrick (NYU), Darien Shanske (UC-Davis; Google Scholar) & Thalia Spinrad (NYU), The Moores Lost Their Claim and Moore, 184 Tax Notes Fed. 1509 (Aug. 19, 2024): In this article, the authors analyze the logic of Moore and
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Morse: How Late Is Too Late To Challenge Old Tax Regs?
Susan Morse (Texas; Google Scholar), How Late Is Too Late to Challenge Old Tax Regs?, 184 Tax Notes Fed. 1235 (Aug. 12, 2024): In this report, Morse examines the six-year default limitations period for claims against the federal government, which the government can invoke to defend against administrative procedure challenges and other claims in tax
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Morse: How Late Is Too Late To Challenge Old Tax Regs?
Susan Morse (Texas; Google Scholar), How Late Is Too Late to Challenge Old Tax Regs?, 184 Tax Notes Fed. 1235 (Aug. 12, 2024): In this report, Morse examines the six-year default limitations period for claims against the federal government, which the government can invoke to defend against administrative procedure challenges and other claims in tax
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July’s Tax Reflections With Reuven Avi-Yonah
Reuven S. Avi-Yonah (Michigan; Google Scholar): Taxing the Superrich After Moore, 184 Tax Notes 61 (July 1, 2024): Avi-Yonah proposes how to tax the wealthiest members of society in a constitutional manner in the wake of the Moore v. United States decision. Taxation With Realization After Moore, 184 Tax Notes 69 (July 1, 2024): Avi-Yonah considers
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July’s Tax Reflections With Reuven Avi-Yonah
Reuven S. Avi-Yonah (Michigan; Google Scholar): Taxing the Superrich After Moore, 184 Tax Notes 61 (July 1, 2024): Avi-Yonah proposes how to tax the wealthiest members of society in a constitutional manner in the wake of the Moore v. United States decision. Taxation With Realization After Moore, 184 Tax Notes 69 (July 1, 2024): Avi-Yonah considers
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2023 Tax Journal Rankings: Tax Law Review Is #1, Virginia Tax Review Is #2
Washington & Lee has just released the 2023 tax law review rankings of six major tax journals: Columbia Journal of Tax Law (“Columbia”) Elder Law Review (“Illinois”) Tax Law Review (“NYU”) Tax Lawyer (“ABA”) Tax Notes Federal (“Tax Notes”) Virginia Tax Review (“Virginia”) The rankings are based on citations to articles published in 2019-2023 (methodology):
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2023 Tax Journal Rankings: Tax Law Review Is #1, Virginia Tax Review Is #2
Washington & Lee has just released the 2023 tax law review rankings of six major tax journals: Columbia Journal of Tax Law (“Columbia”) Elder Law Review (“Illinois”) Tax Law Review (“NYU”) Tax Lawyer (“ABA”) Tax Notes Federal (“Tax Notes”) Virginia Tax Review (“Virginia”) The rankings are based on citations to articles published in 2019-2023 (methodology):