Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Daily
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Newton Reviews Kleiman, Sarkar & Satterthwaite’s “Taxing Nannies”
Deanna S. Newton (Pepperdine) reviews Taxing Nannies by Ariel Kleiman (USC; Google Scholar), Shayak Sarkar (UC-Davis; Google Scholar), and Emily A. Satterthwaite (Georgetown; Google Scholar): Read the full review here. In Taxing Nannies, the authors Kleiman, Sarkar, and Satterwhite initiate an important conversation about the nanny tax by analyzing the preferences and perspectives of nannies themselves.
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Osofsky Presents “Automated Agencies,” Co-Authored with Blank, at UNC Law Book Launch
Leigh Osofsky (North Carolina; Google Scholar) presents Automated Agencies: The Transformation of Government Guidance (Cambridge Univ. Press 2025), co-authored with Joshua Blank (UC–Irvine; Google Scholar), at a UNC Law book launch event on November 21, 2025: Speaking at a book release event on November 21, Osofsky detailed findings from Automated Agencies: The Transformation of Government Guidance. Federal agencies
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Sam Presents “Taxation, Market Failure, and the Constitution” Today at Columbia
Erick J. Sam (Utah) presents Taxation, Market Failure, and the Constitution at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love: If you would like a copy of the draft, please email Prof. Erick Sam, erick.sam@law.utah.edu, or Alykhan Pirani, anp2159@columbia.edu. The Colloquium will meet from 4:20 to 6:10 p.m. in room 103 of William
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Bloomberg: IRS Issues Notice on Foreign Subsidiary Taxable Year Change
Bloomberg: IRS Issues Notice on Foreign Subsidiary Taxable Year Change: The IRS announced Tuesday it intends to issue proposed regulations on the 2025 GOP tax law’s elimination of a rule that allowed certain foreign subsidiaries of US companies to elect their tax year. Notice 2025-72 previews proposed regulations the agency will put out to clarify how
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Bloomberg: IRS Seeks Comments on New Tax Credit for Education Scholarships
Bloomberg: IRS Seeks Comments on New Tax Credit for Education Scholarships: The IRS is seeking comments on a new tax benefit for donors who give to non-profits that expand access to private schools. Scholarship granting organizations typically provide scholarships for low-to-middle income K-12 students to attend private schools. Donors who give cash to these groups
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Bloomberg: Treasury, IRS to Release Wave of New Guidance in Coming Months
Bloomberg, Treasury, IRS to Release Wave of New Guidance in Coming Months: Guidance documents on bonus depreciation, tax-exempt status, and international topics are among a barrage expected in the coming months from the Treasury Department and IRS, Ken Kies, assistant Treasury secretary for tax policy, told tax executives. The IRS is prioritizing guidance to implement
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OECD updates Model Tax Convention to reflect rise of cross-border remote work and clarify taxation of natural resources
OECD, OECD updates Model Tax Convention to reflect rise of cross-border remote work and clarify taxation of natural resources: The OECD has released an update to the Model Tax Convention on Income and on Capital, providing new and detailed guidance on short-term cross-border remote work and on the taxation of income from natural resource extraction.
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Bloomberg: Delaware Approves Business Tax Decoupling to Avoid Revenue Loss
Bloomberg, Delaware Approves Business Tax Decoupling to Avoid Revenue Loss: Delaware enacted legislation Wednesday to decouple the state from some federal business tax incentives after a debate over whether the move would drive businesses away from the small but corporate-friendly state. The Democratic-controlled Senate voted 14-6, along party lines, to approve H.B. 255, which Gov. Matt
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Chodorow: “Saban, Pope, and the Benefits Theory of Taxation”
Adam Chodorow (Arizona State; Google Scholar), Saban, Pope, and the Benefits Theory of Taxation, 57 Ariz. St. L.J. 171 (2025): As a condition for receiving federal highway funding, Congress requires states to spend the revenues they raise from road users on the roads. Congress justified this condition, in part, because wanted federal money to supplement—not replace—state money
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Osofsky: “Wellness and The Tax Law”
Leigh Osofsky (North Carolina; Google Scholar), Wellness and The Tax Law, 59 Ga. L. Rev. 443 (2025): The tax law has long provided extensive subsidies for “medical care.” These subsidies cost the government hundreds of billions of dollars a year. The definition of medical care, which is at the heart of these subsidies, originated many decades
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Avi-Yonah: “Regulatory Taxation And The Tariffs”
Reuven S. Avi-Yonah (Michigan, Google Scholar), Regulatory Taxation And The Tariffs, U. of Mich. L. & Econ. Research Paper (forthcoming 2026): In Learning Resources Inc. v. Trump , the Supreme Court will decide whether the president has the authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs. The statute authorizes the president
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JOTWELL: TAX: Crane reviews “Relics Reevaluated: How to think about Tariffs in a World Dominated by the Income Tax”
Charlotte Crane reviews Reuven Avi-Yonah (Michigan, Google Scholar), Doron Norotzki (Akron, Google Scholar), & Tamir Shana (College of Management, Google Scholar), From Relic to Relevance, The Resurgence of Tariffs, 77 U. Cal. L.J. __ (forthcoming 2026), available at SSRN (Mar. 10, 2025). There’s a lot of confusion about the justifications for and the consequences of
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Harpaz: “Global Tax Wars in the Digital Era”
Assaf Harpaz (Georgia), Global Tax Wars in the Digital Era, 75 Am. U. L. Rev. 77 (2025): The digital economy fundamentally disrupts international tax principles that rely on physical presence. When a business earns income abroad, the country of residence (where the taxpayer resides) and the country of source (where income is generated) both have
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Smith: “Abortion and State Taxes: Unexpected Parallelism”
Eric Smith (Weber State), Abortion and State Taxes: Unexpected Parallelism, 78 Okla. L. Rev. __ (forthcoming 2026): In 2018, South Dakota v. Wayfair, Inc., overruled the physical presence rule, a state and local tax doctrine requiring an out-of-state vendor to be physically present in a state before being compelled to collect the state’s sales and use
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Blue J is Hiring a Director of Tax Education
Blue J is hiring a Director of Tax Education: Blue J is the leading generative AI solution for tax professionals. As a B2B SaaS company, our customers are accountants and tax experts who rely on our market-leading software to deliver fast, accurate, and defensible answers to complex tax questions. With the launch of our flagship
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The New Status Quo For IRS Leadership Roles
Bloomberg, Acting or Vacant: The New Status Quo for Leadership Roles at IRS: Top jobs at the IRS in the Trump administration generally have two forms in 2025: vacant or acting. Roughly 30 jobs make up the top brass organizational chart at the agency. Of those, nine are vacant and 11 are filled by employees
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Behavioral Frictions And Limits Of Tax Advice In Tax Regime Choice
This week David Elkins (Netanya; Google Scholar) reviews Kay Blaufus (Leibniz University of Hannover; Google Scholar), Ralf Maiterth (Humboldt University of Berlin), Michael Milde (Leibniz University of Hannover; Google Scholar) & Caren Sureth-Sloane (Paderborn University), Choosing the Wrong Box? Behavioral Frictions and Limits of Tax Advice in Tax Regime Choice (2025). Business entities are ordinarily
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Tax Policy In The Trump Administration
Above the Law, How The One Big Beautiful Tax Bill Changes Retirement Planning For Lawyers Bloomberg, Acting or Vacant: The New Status Quo for Leadership Roles at IRS Bloomberg, Leadership Void Leaves Tax Practitioners Blind to IRS Priorities Bloomberg, OECD Proposes Changes to Global Minimum Tax Deal to Appease US Inequality.org, Trump’s Tax Law Clobbers
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Cincinnati Seeks To Hire A Tenured Or Tenure-Track Tax Prof
University of Cincinnati College of Law Job Search: The University of Cincinnati College of Law invites applications from entry-level and lateral candidates for a full-time, open rank tenure-track or tenured faculty position in tax law with an expected start date of August 15, 2026. Ideal candidates will be able to teach courses in federal income
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Next Week’s Tax Workshops
Monday, August 25: Diane Kemker (Loyola-Chicago; Google Scholar) will present Illness/Wellness, Ableism & Perfectibility in the Tax Code, 93 UMKC L. Rev. ___ (2026), as part of the Pepperdine Tax Policy Workshop Series. If you would like to attend, please contact Deanna Newton. Wednesday, August 27: Alex Zhang (Emory; Google Scholar) will present Racial Integration and Tax
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Cauble: Exceptional Cases And Automated Agencies
Emily Cauble (Wisconsin; Google Scholar), Exceptional Cases (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)): In their recent book, Automated Agencies, Professors Blank and Osofsky offer what the book front matter aptly describes as “the definitive account of how automation
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Pepperdine Tax Policy Workshop Series (Fall 2025)
Here is Deanna Newton‘s lineup for the Fall 2025 Pepperdine Tax Policy Workshop Series: If you would like to attend any of the workshops, please contact Deanna Newton.
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Creighton Seeks To Hire A Tenured Or Tenure-Track Tax Prof
Creighton University College of Law, Faculty Posting: Creighton University School of Law seeks to hire two full-time faculty. The Law School has particular needs in Estate Planning, Health Law, Sports Law, Tax, Wills and Trusts but also is interested in candidates with backgrounds in Commercial Law, Cyber and Technology Law, Human Rights, International Business Transactions,
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Hidden Taxation And The Rise Of The Shadow Fiscal State
Doron Narotzki (Akron; Google Scholar), Hidden Taxation and the Rise of the Shadow Fiscal State, 7 Ariz. St. Corp. & Bus. L.J. ___ (2026): This Article uncovers a new and troubling development in U.S. fiscal governance: the use of executive-imposed tariffs as covert instruments of sovereign debt management and fiscal redistribution. Building on a provocative
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The Tax Insurance Trap
Benjamin Silver (Ph.D. 2024, Chicago; J.D. 2021, Yale; Google Scholar), The Tax Insurance Trap, 2026 Wis. L. Rev. ___: Conventional wisdom holds that tax uncertainty is an unavoidable consequence of our tax laws' complexity. On this view, tax insurance-a financial product allowing taxpayers to shift tax risk to an insurer for a fee-is merely a hedge