Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Daily
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Mazur & Thimmesch: Cooperative Federalism And The Digital Tax Impasse
Orly Mazur (SMU; Google Scholar) & Adam B. Thimmesch (Nebraska; Google Scholar), Cooperative Federalism and the Digital Tax Impasse, 51 Fla. St. U. L. Rev. __ (2023): The digital economy is changing faster than the law can respond and has challenged legal systems worldwide. In the tax space, the digital economy has undermined traditional tax
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Mazur & Thimmesch: Cooperative Federalism And The Digital Tax Impasse
Orly Mazur (SMU; Google Scholar) & Adam B. Thimmesch (Nebraska; Google Scholar), Cooperative Federalism and the Digital Tax Impasse, 51 Fla. St. U. L. Rev. __ (2023): The digital economy is changing faster than the law can respond and has challenged legal systems worldwide. In the tax space, the digital economy has undermined traditional tax
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ABA Tax Section May Meeting Kicks Off Today In Washington, D.C.
This week’s ABA Tax Section 2023 May Tax Meeting (program) kicks off today. A highlight is the Teaching Taxation program on Friday on Taxing the Metaverse: The buzz surrounding the Metaverse—a digital space featuring virtual reality, augmented reality, and other advanced internet technology—has been growing steadily for the past couple of years, but the tax implications of
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ABA Tax Section May Meeting Kicks Off Today In Washington, D.C.
This week’s ABA Tax Section 2023 May Tax Meeting (program) kicks off today. A highlight is the Teaching Taxation program on Friday on Taxing the Metaverse: The buzz surrounding the Metaverse—a digital space featuring virtual reality, augmented reality, and other advanced internet technology—has been growing steadily for the past couple of years, but the tax implications of
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Clausing: Capital Taxation And Market Power
Kimberly A. Clausing (UCLA; Google Scholar), Capital Taxation and Market Power: In recent decades, market power has increased substantially, according to multiple measures that describe industry concentration, mark-ups, and business profitability. While market power can generate benefits, it also raises vexing policy concerns, including the potential for adverse effects on labor markets, income inequality, and
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Clausing: Capital Taxation And Market Power
Kimberly A. Clausing (UCLA; Google Scholar), Capital Taxation and Market Power: In recent decades, market power has increased substantially, according to multiple measures that describe industry concentration, mark-ups, and business profitability. While market power can generate benefits, it also raises vexing policy concerns, including the potential for adverse effects on labor markets, income inequality, and
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Saving The Nonessential With Radical Tax Policy
Rodney P. Mock (Cal Poly) & Kathryn Kisska-Schulze (Clemson; Google Scholar), Saving the Nonessential With Radical Tax Policy, 90 U. Cin. L. Rev. 197 (2021): Under the Internal Revenue Code of 1986, as amended, for-profit entities are distinguishable from tax-exempt entities in that they, among other factors, pursue profits, and enjoy unrestricted commercial activities. The
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Saving The Nonessential With Radical Tax Policy
Rodney P. Mock (Cal Poly) & Kathryn Kisska-Schulze (Clemson; Google Scholar), Saving the Nonessential With Radical Tax Policy, 90 U. Cin. L. Rev. 197 (2021): Under the Internal Revenue Code of 1986, as amended, for-profit entities are distinguishable from tax-exempt entities in that they, among other factors, pursue profits, and enjoy unrestricted commercial activities. The
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Creating A Pro-Tax Story For Racial Equity
Nicholas A. Mirkay (Hawaii; Google Scholar) & Palma Joy Strand (Creighton), Creating a Pro-Tax Story for Racial Equity, 108 Tax Notes St. 343 (Apr. 24, 2023): In this installment of “The Search for Tax Justice” in Tax Notes State, Mirkay and Strand highlight the deep history of contemporary racialized framing of the “taxpayer” identity as
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Creating A Pro-Tax Story For Racial Equity
Nicholas A. Mirkay (Hawaii; Google Scholar) & Palma Joy Strand (Creighton), Creating a Pro-Tax Story for Racial Equity, 108 Tax Notes St. 343 (Apr. 24, 2023): In this installment of “The Search for Tax Justice” in Tax Notes State, Mirkay and Strand highlight the deep history of contemporary racialized framing of the “taxpayer” identity as
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Tax Law Review Publishes New Issue
The Tax Law Review has published a new issue (Vol. 75, No. 2 (Spring 2022)): Brian Galle (Georgetown; Google Scholar) & Yair Listokin (Yale; Google Scholar), Monetary Finance, 75 Tax L. Rev. 137 (2022) (reviewed by David Elkins (Netanya, visiting NYU) here) Wei Cui (British Columbia; Google Scholar), New Puzzles in International Tax Agreements, 75 Tax L. Rev. 201 (2022)
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Tax Law Review Publishes New Issue
The Tax Law Review has published a new issue (Vol. 75, No. 2 (Spring 2022)): Brian Galle (Georgetown; Google Scholar) & Yair Listokin (Yale; Google Scholar), Monetary Finance, 75 Tax L. Rev. 137 (2022) (reviewed by David Elkins (Netanya, visiting NYU) here) Wei Cui (British Columbia; Google Scholar), New Puzzles in International Tax Agreements, 75 Tax L. Rev. 201 (2022)
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Galle: Incentive-Compatible Inflation Policy
Brian D. Galle (Georgetown; Google Scholar), Incentive-Compatible Inflation Policy, 108 Cornell L. Rev. Online ___ (2023): In most highly-developed economies, governments have handed management of inflation entirely over to their central banks, and for good reason. With inflation largely beaten by central bankers for nearly five decades, there has been little effort to design, let
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Galle: Incentive-Compatible Inflation Policy
Brian D. Galle (Georgetown; Google Scholar), Incentive-Compatible Inflation Policy, 108 Cornell L. Rev. Online ___ (2023): In most highly-developed economies, governments have handed management of inflation entirely over to their central banks, and for good reason. With inflation largely beaten by central bankers for nearly five decades, there has been little effort to design, let
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SSRN Tax Professor Rankings
SSRN has updated its monthly ranking of 750 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database. Here is the new list (through April 1, 2023) of the Top 25 U.S. Tax Professors in two of the SSRN categories: all-time downloads
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SSRN Tax Professor Rankings
SSRN has updated its monthly ranking of 750 American and international law school faculties and 3,000 law professors by (among other things) the number of paper downloads from the SSRN database. Here is the new list (through April 1, 2023) of the Top 25 U.S. Tax Professors in two of the SSRN categories: all-time downloads
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Tax Prof Twitter Problems: Suspension, Hack
Andy Grewal (Iowa) and Daniel Hemel (NYU) are two of the more active Tax Profs on twitter. Both have lost access to their accounts for different reasons. Twitter suspended Andy's account (@AndyGrewal) as a result of a twitter conversation with a friend (Andrew Dhuey) over the proper response to the alleged controversy around Justice Thomas.
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Tax Prof Twitter Problems: Suspension, Hack
Andy Grewal (Iowa) and Daniel Hemel (NYU) are two of the more active Tax Profs on twitter. Both have lost access to their accounts for different reasons. Twitter suspended Andy's account (@AndyGrewal) as a result of a twitter conversation with a friend (Andrew Dhuey) over the proper response to the alleged controversy around Justice Thomas.
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Luke Reviews Marian’s Taxing Data
Charlene Luke (Florida; Google Scholar), Tax Design for a Data-Rich World (JOTWELL) (reviewing Omri Marian (UC-Irvine; Google Scholar), Taxing Data, 47 BYU L. Rev. 511 (2022)): In Taxing Data, Omri Marian argues that taxing data-rich markets requires rejecting income taxation—not only as implemented but also “in its optimal theoretical form”—as the best proxy for ability
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Luke Reviews Marian’s Taxing Data
Charlene Luke (Florida; Google Scholar), Tax Design for a Data-Rich World (JOTWELL) (reviewing Omri Marian (UC-Irvine; Google Scholar), Taxing Data, 47 BYU L. Rev. 511 (2022)): In Taxing Data, Omri Marian argues that taxing data-rich markets requires rejecting income taxation—not only as implemented but also “in its optimal theoretical form”—as the best proxy for ability
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Avi-Yonah Posts Three Tax Papers On SSRN
Reuven S. Avi-Yonah (Michigan; Google Scholar) has posted three tax papers on SSRN: Follow the Money: Why Is International Tax Bilateral?: International tax law has traditionally been built upon bilateral treaties and unilateral actions, while trade law has traditionally been multilateral and international investment law has been bilateral but with Most Favored Nation (MFN) clauses that
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Avi-Yonah Posts Three Tax Papers On SSRN
Reuven S. Avi-Yonah (Michigan; Google Scholar) has posted three tax papers on SSRN: Follow the Money: Why Is International Tax Bilateral?: International tax law has traditionally been built upon bilateral treaties and unilateral actions, while trade law has traditionally been multilateral and international investment law has been bilateral but with Most Favored Nation (MFN) clauses that
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Lesson From The Tax Court: Better Deals With Appeals
One recurring lesson I teach in Tax Practice and Procedure is that you generally serve your client better by resolving their issues at the lowest level. That requires helping them be realistic in understanding the range of potential outcomes. It requires an understanding that IRS offices, such as the Office of Appeals, generally have more
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Lesson From The Tax Court: Better Deals With Appeals
One recurring lesson I teach in Tax Practice and Procedure is that you generally serve your client better by resolving their issues at the lowest level. That requires helping them be realistic in understanding the range of potential outcomes. It requires an understanding that IRS offices, such as the Office of Appeals, generally have more