Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Daily
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Aprill & Horwitz: Fiduciaries, Constituencies, And The Duty Of Loyalty In Modern Nonprofits
Ellen P. Aprill (Loyola-L.A.; Google Scholar) & Jill R. Horwitz (UCLA; Google Scholar), Fiduciaries, Constituencies, And The Duty Of Loyalty In Modern Nonprofits, Nonprofit Policy Forum: A fiduciary of a charity has a fundamental duty to act in good faith and in a manner the fiduciary reasonably believes to be in the best interests of…
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Scuderi’s Sovereignty, Outer Space, And Taxation
This week, Blaine G. Saito (Ohio State; Google Scholar) reviews a new work by Erika Isabella Scuderi (Florida), Sovereignty, Outer Space, And Taxation, 104 Neb. L. Rev. ___ (2026). Space is a new frontier of commercial activity. Companies now launch satellites for profit. Others seek to travel to the moon, Mars, and beyond perhaps for…
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Tax Policy In The Trump Administration
ABA Journal, New Law Preserves SALT and QBI Deductions, Avoids Large Tax Hikes For Law Firms Bloomberg, IRS Chief Says Direct File Is ‘Gone,’ Other Audit Tech Is Coming Bloomberg, More Tax Rules May Make Treasury’s Hit List Bloomberg, Piketty Tells Starmer to Introduce a Wealth Tax in the UK Cato Institute, Inflation Can Increase…
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Examining The Circuit Split On Conservation Easements
Harry A. Mullen IV (J.D. 2025, Georgia State), Tax Evasion and Judicial Oversight: Examining the Circuit Split on Conservation Easements, 41 Ga. St. U. L. Rev. 457 (2025): Conservation easements have long been an attractive tool for those seeking to minimize their tax bill. After all, it is a low-cost method of getting a sizeable tax…
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Pay Taxes and Get Deported: Undocumented Immigrants and Tax Privacy
Samuel D. Brunson (Loyola-Chicago; Google Scholar), Pay Taxes and Get Deported: Undocumented Immigrants and Tax Privacy, The IRS has more information about more Americans than any other agency in the United States. Historically, other administrative agencies have targeted that IRS data to pursue their mandates or, at times, to pursue their enemies. In the wake of a…
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Fired Davis Polk Tax Associate: Harvard Taught Me To Speak Out. Big Law Fired Me When I Did.
Following up on my previous post, Davis Polk Axes Tax Associate Who Published Op-Eds Criticizing Trump: ‘Was He Heroic, Naive Or Full Of Himself?’: Harvard Crimson Op-Ed: Harvard Taught Me to Speak Out. Big Law Fired Me When I Did., by Ryan W. Powers (J.D. 2023, Harvard): Last month, I was fired from my corporate law job. My offense?…
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Divorcing Families Need Their Slice Of The TCJA Reversions
John C. McDonald (BYU), Into the Sunset: Divorcing Families Need Their Slice of the TCJA Reversions, 50 BYU L. Rev. 531 (2024): On its path to sufficiently offsetting its major cut to the corporate income tax rate in 2017, Congress turned to a surprising source for funds: the alimony support payments of recently divorced families.…
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IRS Heads Of Large Business And Professional Responsibility Units Placed On Leave Pending Investigation Of Their Conduct Against Republicans
Bloomberg Tax, IRS Heads of Large Business Unit, Tax Pro Oversight Put on Leave: Two highly placed IRS leaders were put on administrative leave Tuesday, according to a person familiar with the situation. Holly Paz, the commissioner of Large Business and International Division, and Elizabeth Kastenberg, acting director of the Office of Professional Responsibility, were…
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Parsons: Taxing Social Data
Following up on my previous post, Valuing Social Data [124 Colum. L. Rev. 993 (2024)]: Amanda Parsons (Colorado; Google Scholar), Taxing Social Data: Data about people, or social data, powers the digital economy. Social data allows companies to predict and modify human behavior, producing economic value for themselves and wealth for their investors. Tax law…
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Congress’s Authority To Regulate State And Local Taxation
Bradley W. Joondeph (Santa Clara; Google Scholar), Congress's Authority To Regulate State And Local Taxation, 79 Tax Law. ___ (2026): The current consensus is that Congress can generally regulate how state and local governments impose taxes. The Supreme Court has never squarely so held, but the justices have declared as much several times. If we…
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What Went Wrong In The Apple State Aid Case: Part 2 — Suggested Reforms
Ruth Mason (Virginia; Google Scholar) & Stephen Daly (King's College London; Google Scholar), What Went Wrong in the Apple State Aid Case and How to Fix It — Part 2: Suggested Reforms, 44 Va. Tax Rev. 421 (2025): This Article criticizes the reasoning of the European Commission and EU courts in the Apple state aid case and…
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Sovereignty, Outer Space, And Taxation
Erika Isabella Scuderi (Florida; Google Scholar), On Sovereignty, Outer Space, and Taxation, 104 Neb. L. Rev. ___ (2026): This article offers a comprehensive review of states' taxing powers in outer space. Beginning with an analysis of the legal status of airspace and outer space, the study assesses the resilience of traditional fiscal attachments, including residence-based…
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Reexamining Triangular B Reorganizations
Doron Narotzki (Akron; Google Scholar) & Tamir Shanan (Haim Striks; Google Scholar), Reexamining Triangular B Reorganization: Requirements and Potential Tax Traps or a Time to Revisit Its Favorable Application, 24 UC Davis Bus. L.J. 167 (2024): One of the most commonly executed changes in the structure of U.S. corporations is an exchange of stock of…
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OBBBA: Remittance Tax Goes From Highly Problematic To Barely There
Laura Snyder (Association of Americans Resident Overseas), OBBBA: Remittance Tax Goes From Highly Problematic to Barely There, 188 Tax Notes Fed. 31 (July 7, 2025): The various versions of One Big Beautiful Bill contained a tax on remittance transfers. This article compares the different versions of the tax as it was modified in each version of…
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Christians & Singer: Critical Questions In Tax Policy Analysis
Allison Christians (McGill; Google Scholar) & Samuel Singer (Ottawa; Google Scholar), The Role of Critical Questions in Tax Policy Analysis, 72 Can. Tax J. 825 (2024): This article explains what it means to ask critical tax questions, in order to show that critical tax studies are an essential component of good tax policy analysis. We demonstrate that, grounded in the…
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How To Turn 100 Million Workers Into Passive Shareholders
Joshua Cutler (Boise; Google Scholar), How To Turn 100 Million Workers Into Passive Shareholders: It is widely recognized that the United States retirement system has rapidly shifted away from defined benefit pension plans and towards defined contribution plans and Individual Retirement Accounts. Less recognized is the fact that most of these retirement plans now invest…
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The Top Five New Tax Papers
There is a bit of movement in this week’s list of the Top 5 Recent Tax Paper Downloads, with a new paper debuting on the list at #5. The #1 paper is #443 among 12,161 tax papers in all-time downloads. [981 Downloads] Policies to Reduce Federal Budget Deficits by Increasing Economic Growth, by Douglas Elmendorf…
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Addressing The Exclusion Of Undocumented Immigrants From Income Tax Benefits And Designing A Solution
Gabriela Amaral (J.D. 2024, Cardozo), Who Gets to Reap What They Sow? Addressing the Exclusion of Undocumented Immigrants from Income Tax Benefits and Designing a Solution, 30 Cardozo J. Equal Rts. & Soc. Just. 747 (2024): Support for immigration into the United States and for advancing the ways that people can gain legal status in…
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Weekly SSRN Tax Article Review And Roundup: Harpaz Reviews Regulatory Mismatches In The US And EU By Knoll, Mason & Schoen
This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Michael S. Knoll (Penn; Google Scholar) Ruth Mason (Virginia; Google Scholar), and Wolfgang Schön (Max Planck), Regulatory Mismatches in the United States and the European Union. Interstate commercial actors often face regulatory mismatches, which refer to differences in legal regulations between states. Regulatory mismatches are…
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Tax Policy In The Trump Administration
Bloomberg, Trump Weighing Effort to Remove Capital Gains Tax on Home Sales CNN, New Tax Law Increases Big Beyond-the-Grave Tax Break for the Wealthy Institute on Taxation and Economic Policy, Americans Want to Know Which Corporations Aren’t Paying Taxes, but House Republicans Want to Keep this Information Secret Institute on Taxation and Economic Policy, How…
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Colon: ETFs Join The Swap Fund Pantheon
Jeffrey M. Colon (Fordham), ETFs Join the Swap Fund Pantheon, ETFs have begun to challenge mutual funds as the dominant public pooled asset vehicle. Their constant liquidity, exposure to an ever widening range of investment strategies, and highly touted tax efficiency have driven the explosive growth in the assets under management of ETFs over the…
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Athletic Performance And State Tax Rates: Why NBA Players Perform Worse In High-Tax States
Michael Conklin (Texas A&M; Google Scholar), Athletic Performance and State Tax Rates: Why NBA Players Perform Worse in High-Tax States, 21 Md. J. Bus. & Tech. L. ___ (2025): This Article presents the results of a novel empirical study measuring the impact of state income tax rates on professional athletic performance. While prior scholarship established…
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Trump’s One Big Beautiful Bill Act Invites States To Tax Bigger Share Of Foreign Profits
Bloomberg Law, Tax Law Invites States to Pursue Bigger Share of Foreign Profits: President Donald Trump’s tax and spending law opens the door for states to follow the federal government’s lead and tax a larger portion of international corporate income, vexing some business groups that argue states will exceed their taxing authorities on business income…
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Singer & Christians: Critical Perspectives In Canadian Tax Law
Samuel Singer (Ottawa; Google Scholar) & Allison Christians (McGill; Google Scholar), Critical Perspectives in Canadian Tax Law, in Critical Conversations in Canadian Public Law (University of Ottawa Press 2025): The purpose of this article is to spotlight the role of critical tax law scholarship in Canada. We argue that critical perspectives are essential to identifying inequities…
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Vinita Singh Joins Minnesota Tax Faculty
Minneapolis: Minnesota Law Welcomes Vinita R. Singh to the Faculty in 2025: The University of Minnesota Law School is pleased to announce Vinita R. Singhwill join the faculty as an associate professor of law in the fall of 2025. Professor Singh studies economic statecraft, with an emphasis on examining how federal income taxation can be used…