Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Kiel: Americans Bear Nearly the Entire Cost of Tariffs
The Kiel Institut (Germany) has published a new policy report, America’s Own Goal: Who Pays the Tariffs? (See coverage in the Wall Street Journal here.) Here are some of the highlights: • The 2025 US tariffs are an own goal: American importers and consumers bear nearly the entire cost. Foreign exporters absorb only about 4%
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2025 IFA International Tax Student Writing Award; Call For Entrants In 2026 Competition
The winner of the International Fiscal Association’s 2025 International Tax Student Writing Competition is: Jacob Cohen (UVA / Skadden): Crystals and Mud in International Taxation: Why the Principal Purpose Test’s Impact Will Not Meet Expectations. Faculty Sponsor: Ruth Mason
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Freedman, Arman Kouchekinia & Neumark: Understanding the Employment Effects of Opportunity Zones
Matthew Freedman (UC Irvine, Econ.), Noah Arman Kouchekinia (UC Irvine, Econ.) & David Neumark (UC Irvine, Econ.), Understanding the Employment Effects of Opportunity Zones, NBER Working Paper No. 34589 (Dec. 2025):
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Madoff on Policy Fixes for Charitable Giving
Ray Madoff, Interview, With Less Charitable Giving Flowing Directly to Charities, a Tax Policy Scholar Suggests Some Policy Fixes, The Conversation (Jan. 6, 2026):
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SSRN Review & Roundup: Narotzki Reviews McGee, Yuzbasi, Kisa & Benk’s The Role of Emotions in Tax Evasion
This week, Doron Narotzki (Akron; Google Scholar) reviews Robert W. McGee (Fayetteville State University), Bahadir Yuzbasi (Inonu University), Ökkes Kisa (Inonu University) & Serkan Benk (Inonu University), The Role of Emotions in Attitudes Toward Ethics of Tax Evasion: An Empirical Study, 10 Int’l J. Pub. Fin. 325 (2025). McGee, Yuzbası, Kısa, and Benk offer a
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Schoen: Tariffs and the International Tax Order
Wolfgang Schoen (Max Planck), Tariffs and the International Tax Order (Jan, 12, 2026), Working Paper of the Max Planck Institute for Tax Law and Public Finance No. 2026-01, available on SSRN. Tariffs – or customs duties – have become a prominent feature of the international tax world in 2025. While their use had been restricted
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Borden: A Critical Analysis of Alternative Section 1031 Proximate-Exchange Structures
Brad Borden (Brooklyn) has published a new piece, A Critical Analysis of Alternative Section 1031 Proximate-Exchange Structures, 22 UC Law SF Bus. L. J. 81 (2025):
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Avi-Yonah and Mazzoni on the Origins of U.S. Retaliatory Tax Policy
Reuven S. Avi-Yonah and Gianluca Mazzoni (Michigan) have published “The Forgotten Weapon: Section 891 And the Origins of U.S. Retaliatory Tax Policy” in Tax Notes. Here is the introduction: The original version of the One Big Beautiful Bill Act (P.L. 119-21) included section 899, which would have imposed retaliatory taxes on individuals and corporations from
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Revealing Tax Evasion: Evidence from Indonesian Firms
Christopher Hoy (World Bank), Filip Jolevski (George Mason), and Anthony Obeyesekere (World Bank) have posted “Revealing Tax Evasion: Experimental Evidence from a Representative Survey of Indonesian Firms” on SSRN. Here is the abstract: Measuring tax evasion by firms is notoriously difficult: direct questions yield biased responses while administrative data captures only detected violations. This paper
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Zhang: Racial Integration and Tax Exemption
Alex Zhang (Emory) argues that the government has used tax exemptions to exacerbate racial equality
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Harpaz Presents Two Papers on AI and Sovereignty at AALS and JILSA
This week, Assaf Harpaz (Georgia) presented two new papers: Abstracts follow.
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Clarke & Marks at AALS: Tax Regulations After Loper Bright
On January 6, 2026, Noah Marks (UNC) presented Tax Regulations After Loper Bright: A Preliminary Analysis (with Conor Clarke (Wash. U.)) at the New Voices in Administrative Law Workshop at the Association of American Law Schools (AALS) Annual Meeting in New Orleans. The abstract follows.
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Agrawal & Chen: State and Local Tax Policy in a Time of Telework
David R. Agrawal (UC Irvine) & Xinyu Chen (Michigan), State and Local Tax Policy in a Time of Telework (Dec. 23, 2025), available at SSRN State and local tax systems are constrained by the geographic location of individuals and economic activity. The rise of telework weakens this linkage by decoupling a worker’s state of residence
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SSRN Review & Roundup: Saito Reviews Repetti’s Private Equity, Health Calamity
This week, Blaine Saito (Ohio State) reviews a new work by James R. Repetti (Boston College), Private Equity, Health Calamity: How Our Tax Laws Aid Private Equity Investment in Hospitals and Nursing Homes (Dec. 15, 2025): The reach of private equity (PE) continues to expand into nearly every sector of the American economy. For example, the Trump
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Galle, Gamage & Shanske: Correcting the Record: Responding to Some Legal Arguments About the 2026 Billionaire Tax Act
Brian D. Galle (UC Berkeley), David Gamage (Missouri), & Darien Shanske (UC Davis), Correcting the Record: Responding to Some Legal Arguments About the 2026 Billionaire Tax Act (Dec. 31, 2025, revised Jan. 9, 2026), available at SSRN If adopted by California voters in November of 2026, the 2026 California Billionaire Tax Act (CBTA) would impose
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Appleby Presents “Constitutional Commandeering” Today at AALS
Andrew Appleby (Tennessee) presents Constitutional Commandeering during the Section on State and Local Government Law’s main session, Crisis and Capacity: State and Local Government Law in a Time of Constraint, today at AALS: This Article traces the evolution of the anti-commandeering doctrine and its increasing relevance to federal limitations on state taxation, before exploring the role of
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Cahill: Home Sweet Home Deduction
Collin Cahill (J.D. 2025, Ohio State), Home Sweet Home Deduction, 25 U.C. Davis Bus. L.J. 29 (2025):
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Loayza Jordán presents “International Tax Peace” at JILSA Annual Meeting
Fernando Loayza Jordán (Drexel-Kline, Yale) presented “International Tax Peace” on January 6 at the Junior International Law Scholars Association annual meeting at the University of Hawai’i in Honolulu. Here is the abstract:
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Elkins: Embracing Tax Avoidance
David Elkins (Netanya), Embracing Tax Avoidance, 34 U. Fla. J.L. & Pub. Pol’y 327 (2024):
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Gopinath and Neiman, “The Incidence of Tariffs: Rates and Reality” (NBER)
Gita Gopinath (Harvard) and Brent Neiman (Chicago) have a new NBER working paper, “The Incidence of Tariffs: Rates and Reality.” Here is the abstract: In 2025, statutory tariff rates on U.S. imports rose to levels not seen in over one hundred years. What are the implications for prices? On the one hand, shipping lags, exemptions,
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Eckstein, Granov & Shillo: Leave the Door Open? Towards a Context-Based Approach to the Revolving Doors
Asaf Eckstein (Hebrew U. Jerusalem), Ziv Granov (Hebrew U. Jerusalem) & Ariel Shillo (Hebrew U. Jerusalem), Leave the Door Open? Towards a Context-Based Approach to the Revolving Doors, __ Ari. St. L.J. __ (forthcoming 2026) (with a related post at the CLS Blue Sky Blog):