Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Daily
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Aprill: Rejecting Pro-Taxpayer Regulations Under Loper Bright
Ellen P. Aprill (Loyola-L.A.; Google Scholar), 2025 Erwin N. Griswold Lecture Before the American College of Tax Counsel: Rejecting Pro-Taxpayer Regulations under Loper Bright: Rejecting Pro-Taxpayer Regulations under Loper Bright: In Memorial Hermann Accountable Care Organization v. Commissioner (“Memorial Hermann”), the Fifth Circuit relied on Loper Bright v. Raimondo (Loper Bright) to reject the appellant
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The Supreme Court’s 2024 Term In Tax
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC), The Supreme Court’s 2024 Term in Tax, 188 Tax Notes Fed. 781 (Aug. 4, 2025): In this article, Cummings examines the 2024 term of the Supreme Court, in which it seems to have returned to the norm of rendering a few “boring” tax decisions, although he
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Leff: The IRS Is Upholding A Core Liberal Principle In Permitting Churches To Endorse Political Candidates From The Pulpit
New York Times Op-Ed: The I.R.S. Is Trying to Uphold a Core Liberal Principle, by Benjamin M. Leff (American; Google Scholar): Last month the Internal Revenue Service did something remarkable: It proposed allowing houses of worship to engage in political speech and even endorse candidates without jeopardizing their ability to accept tax-deductible contributions. This proposal — which
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Fourth Circuit: Maryland Law Barring Disclosure Of Costs Of Internet Advertising Is Unconstitutional
Jonathan H. Adler (William & Mary), Maryland Can Tax Internet Advertising, But It Cannot Prevent Advertisers from Disclosing Cost of Tax: On Friday, in Chamber of Commerce v. Lierman, the U.S. Court of Appeals for the Fourth Circuit concluded that Maryland’s law barring internet advertisers from disclosing the costs of Maryland’s internet advertising tax to
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Facebook Decision Enables IRS To Seek Commensurate With Income Enforcement Against Meta
Stephen L. Curtis (Cross Border Analytics), Reuven S. Avi-Yonah (Michigan; Google Scholar) & David G. Chamberlain (Cal Poly; Google Scholar), Facebook Decision Enables IRS to Seek CWI Enforcement Against Meta, 188 Tax Notes Fed. 709 (Aug. 4, 2025): In this report, the authors explain how the Tax Court’s recent decision in the Facebook transfer pricing case —
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NY Times: SpaceX Gets Billions From The Government, Pays Little In Taxes
New York Times, SpaceX Gets Billions From the Government. It Gives Little to Nothing Back in Taxes.: Elon Musk’s rocket company relies on federal contracts, but years of losses have most likely let it avoid paying federal income taxes, according to internal company documents. SpaceX, Elon Musk’s rocket and satellite internet company, has received billions
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Suffolk Seeks To Hire An Entry-Level Tenure-Track Tax Prof
Suffolk University, Tenure Track Faculty Position: Suffolk University Law School in Boston seeks to fill an entry-level, tenure-track faculty position, starting in 2026-2027. Seeking candidates with strong academic and professional backgrounds who show promise of high achievement in scholarship, teaching, and service. We welcome future colleagues who would contribute to any of the faculty’s broad
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WaPo: The NCAA Should Lose Its Nonprofit Status
Washington Post Op-Ed: This Billion-Dollar Sports Behemoth Should Not be a Nonprofit, by Scott Hodge (Former President, Tax Foundation): Despite its nonprofit status, the National Collegiate Athletic Association is big business. Its 2024 financial statement shows that it earned more than $1.3 billion in income from the sale of television rights, advertising, tickets, merchandise and membership
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The Top Five New Tax Papers
This week’s list of the Top 5 Recent Tax Paper Downloads is the same as last week’s list. [441 Downloads] Hyosung Corp.: The Tax Treaty-Domestic Tax Law Interaction, by Dhruv Janssen-Sanghavi (Maastricht; Google Scholar) [412 Downloads] Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures,
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WSJ: Lawyers Are On Edge Over Estate Tax Mistake That Can Cost A Family $6 Million
Wall Street Journal, The Estate Tax Mistake That Can Cost Families Millions: One family ended up with an extra tax bill of $1.5 million, and now estate lawyers are on edge. The U.S. tax code is generous when it comes to passing down money to heirs tax-free, and it has only become more so under
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews Hasen’s Pricing Low-Income Resource Volatility
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by David Hasen (Florida), Pricing Low-Income Resource Volatility. Economists and policymakers historically have approached households as static constructs, governed by rhetorics of persistent poverty or a linear trajectory of upward mobility. This perspective is complicated by current research that emphasizes contingency and precarity as
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Tax Policy In The Trump Administration
Bloomberg, IRS Chief’s Gaffes, Sudden Exit Roil the Fractured Tax Agency Bloomberg, IRS Vets and Wild Cards: Trump’s Options for Replacing Long Bloomberg, NY, NJ Fail in Court Bid to Keep Their SALT Cap Workarounds Bloomberg, Trump Tax Law Squeezes Poor, Boosts Income for Wealthy, CBO Says Law360, Midyear Review: A Look At The Tax
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Townsend: Federal Tax Procedure 2025
Jack Townsend, formerly an adjunct tax professor at the University of Houston Law School, has posted to SSRN his annual editions of the Federal Tax Procedure book: Student 2025 Edition (806 pages): This edition has no footnotes and is designed for the federal tax procedure student. I present the core tax procedure information that I
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Granato: Conflicting Values In Judicial Valuations
Andrew Granato (Yale; Google Scholar), Conflicting Values In Judicial Valuations: Do courts employ finance neutrally and consistently, or do different courts fashion financial tools in court-specific ways? I assemble 20 years (52,000 pages) of judicial opinions, legal briefs, and expert reports from three settings where statutes assign courts an ostensibly shared job of valuing business
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Aprill: Misunderstanding National Religious Broadcasters
Ellen P. Aprill (Loyola-L.A.; Google Scholar), Misunderstanding National Religious Broadcasters, 188 Tax Notes Fed. 581 (July 28, 2025): This piece examines the proposed order and joint motion for entry of consent judgment in National Religious Broadcasters v. Commissioner addressing the relationship between the Johnson Amendment, which prohibits campaign intervention for any entity exempt under section 501(c)(3),
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Judge Refuses To Dismiss Class Action Over Misclassifying Underpaid Female And Nonwhite Attorneys As Non-Equity Partners, But Dismisses Tax Withholding Claim
Following up on my previous post, 900-Lawyer Duane Morris Sued For Misclassifying Non-Equity Partners To Shift Business Expenses And Taxes To Underpaid Female And Nonwhite Attorneys: ABA Journal, Nonequity Partner's Unjust Enrichment Suit Against Duane Morris Remains Largely Intact After Judge's Ruling: A federal judge has refused to dismiss a proposed class action lawsuit alleging
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ABA Adopts Resolution Urging Repeal Of Taxes On Menstrual Products
📣 Resolution 507 Adopted by the ABA House of Delegates The ABA urges all governments to repeal taxes on menstrual products (MDCDs) and calls on Congress to ban them nationwide. A step toward menstrual equity and tax justice. Read the full report here: https://t.co/F7qoA6sO9v — ABA Tax Section (@ABATAXSECTION) August 11, 2025
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Zhang: Tax Procedure And Distributive Discourse
Alex Zhang (Emory; Google Scholar), Tax Procedure and Distributive Discourse, 74 Am. J. Compar. L. ___ (2026): This Article develops the concept of procedurally forced distributive discourse, and articulates its values for a legitimate, well-functioning democracy. In classical Athens, citizens dissatisfied with their assigned tax burden could dispute it under the exchange procedure (antidosis). Under an
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Sarah Lawsky’s FREE, Customizable Code And Regs Selected Sections For Any Tax Class Now Includes OBBBA
Sarah Lawsky (Illinois; Google Scholar): The make-your-own Code and Regulations website now contains the law current through July 30, 2025, and therefore is ready to generate books for this fall’s classes. Books you generate through the website will include the changes implemented by Public Law 119-21, enacted on July 4, 2025, including amending and renumbering previously existing
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Winners Of The 2025 Mary Moers Wenig Law Student Writing Competition
ACTEC Foundation, Winners of the 2025 Mary Moers Wenig Student Writing Competition: John T. Rogers, Jr., President of The ACTEC Foundation, and Elizabeth A. Bawden and Gerry W. Beyer, Co-Chairs of the Legal Education Committee of The American College of Trust and Estate Counsel (ACTEC), are pleased to announce the winners of the 2025 Mary Moers Wenig Student Writing Competition.
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Winners Of The 2025 Mary Moers Wenig Law Student Writing Competition
ACTEC Foundation, Winners of the 2025 Mary Moers Wenig Student Writing Competition: John T. Rogers, Jr., President of The ACTEC Foundation, and Elizabeth A. Bawden and Gerry W. Beyer, Co-Chairs of the Legal Education Committee of The American College of Trust and Estate Counsel (ACTEC), are pleased to announce the winners of the 2025 Mary Moers Wenig Student Writing Competition.
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IRS Officials Trade On Confidential Tax-Related Information And Impact Tax Enforcement Outcomes
Cato Institute: IRS Officials’ Stock Holdings and Corporate Tax Outcomes, by Michael Mayberry (Florida; Google Scholar), Eashwar Nagaraj (Florida; Google Scholar) & Scott G. Rane (Florida; Google Scholar): The IRS plays an important role in improving corporate transparency and encouraging corporations to act in the best interests of their shareholders and other stakeholders. The agency makes
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IRS Officials Trade On Confidential Tax-Related Information And Impact Tax Enforcement Outcomes
Cato Institute: IRS Officials’ Stock Holdings and Corporate Tax Outcomes, by Michael Mayberry (Florida; Google Scholar), Eashwar Nagaraj (Florida; Google Scholar) & Scott G. Rane (Florida; Google Scholar): The IRS plays an important role in improving corporate transparency and encouraging corporations to act in the best interests of their shareholders and other stakeholders. The agency makes
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2024-25 Tax Prof Lateral Moves
One of the 14 lateral faculty moves announced in the 2024-25 academic year characterized as “particularly significant/notable” by Brian Leiter (Chicago) is Tax Prof Sarah Lawsky’s move from Northwestern to Illinois. Other lateral Tax Prof moves announced in 2024-25: Andrew Appleby from Stetson to Tennessee Jonathan Choi from USC to Washington University Brian Galle from
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2024-25 Tax Prof Lateral Moves
One of the 14 lateral faculty moves announced in the 2024-25 academic year characterized as “particularly significant/notable” by Brian Leiter (Chicago) is Tax Prof Sarah Lawsky’s move from Northwestern to Illinois. Other lateral Tax Prof moves announced in 2024-25: Andrew Appleby from Stetson to Tennessee Jonathan Choi from USC to Washington University Brian Galle from