Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Podcasts: Bearer-Friend & Polcz on Taxing AI
Jeremy Bearer-Friend (George Washington) and Sarah Polcz (UC Davis) recently discussed their forthcoming article, Sharing the Algorithm: The Tax Solution to Generative AI, on two leading law prof podcasts:
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Satterthwaite Presents Two Essays Today at San Diego
Emily Satterthwaite (Georgetown, SSRN) presents Pooling and Preferences: A Survey of Tax Expert Opinion on Joint Filing and What Does (Some) Optimal Tax Research Say About the Tax Unit? at San Diego today as part of its Tax Law Speaker Series. Monday, April 20, 2026 | noon – 1:00 p.m. PSTWarren Hall 2A, University of San Diegostudents welcome / lunch
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Cauble: Phantom Tax Loopholes
Emily Cauble (Wisconsin), Phantom Tax Loopholes, 27 Fla. Tax Rev. 519 (2024): This Article reports the results of a new survey of 726 U.S. adults designed to gauge people’s intuitions about tax law. Survey respondents consider several scenarios. In each scenario, the survey describes two ways that parties to a transaction can achieve their non-tax objectives.
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JOTWELL: Showdown or Balancing Act: Reconciling Our Commitments to the Tax System and the Legal System
Diane Ring, Showdown or Balancing Act: Reconciling Our Commitments to the Tax System and the Legal System, JOTWELL (Apr. 14, 2026) (reviewing Siddesh Rao (Copenhagen Bus. Sch.), Client-Attorney Privilege: The Last Barrier to Tax Transparency, 18 World Tax J. 1 (2026)): In a world in which information vital to effective tax enforcement is frequently hidden from view, who
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SSRN Review & Roundup: Elkins Reviews Brauner’s Income and Territoriality
This week, David Elkins (Netanya; Google Scholar) reviews a new work by Yariv Brauner (Florida; Google Scholar), Income and Territoriality: A Purpose-Based Reform of Income Sourcing Rules, _ Can. Tax J. _ (forthcoming 2026): It is commonly noted in the literature on international taxation that the international tax regime instituted in the wake of the
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 32 (April 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron:
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Dharmapala Presents “The Origins of the Corporate Income Tax: An Event Study Approach” Today at Irvine
Dhammika Dharmapala (Berkeley) presents The Origins of the Corporate Income Tax: An Event Study Approach at Irvine, as part of its Graduate Tax Policy Colloquium: Professor Dhammika Dharmapala joined Berkeley Law in 2023 from the University of Chicago Law School, where he was the Paul H. and Theo Leffmann Professor of Commercial Law. He serves as Co-Editor of the Journal of
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Tax Workshop Clearinghouse: A Reminder and a Renewed Invitation
A few weeks ago, TaxProf Blog announced a Tax Workshop Clearinghouse, a resource designed to make it easier for workshop and conference organizers to identify scholars with current works in progress, while also giving tax scholars a simple way to indicate that they have projects that would benefit from presentation and feedback. The initial response
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Bouadi & Weare: Overruling the Insular Cases: What About Federal Taxes?
Sumaya H. Bouadi (Withers) and Neil Weare (Right to Democracy) have a new article on SSRN titled “Overruling the Insular Cases: What About Federal Taxes?” Here’s the abstract: The Insular Cases—Supreme Court rulings from the early 1900s addressing the constitutional status of the Territories—are under fire. In 2022, Supreme Court Justice Neil Gorsuch declared “[t]hey
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Bastian and Harvey: The 2021 Child Tax Credit and Consumer Sentiment
Jacob Bastian (Rutgers) and Melody Harvey (Wisconsin) have a new NBER working paper, “When Policy Shapes Perception: The 2021 Child Tax Credit and Consumer Sentiment.” Here is the abstract: Consumer sentiment influences household behavior in important ways, yet we lack causal evidence on whether government policies themselves shape these perceptions. We help fill this gap
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Tariffs in 2025: Short-Run Impacts on the U.S. Economy
Pablo D. Fajgelbaum (UCLA) & Amit Khandelwal (Yale) have a new NBER working paper, “Tariffs in 2025: Short-Run Impacts on the U.S. Economy.” Here is the abstract: In 2025, the U.S. raised average tariff duties from 2.4% to 9.6%, bringing protectionism to its highest level in eighty years. We explore the structure of these tariffs,
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Call for Papers: CUHK-KCL Annual Conference on Tax, Trade, and Investment Law
More information at the full link, but here are the basic details: The Faculty of Law at the Chinese University of Hong Kong (CUHK) and the Dickson Poon School of Law at King’s College London (KCL) will jointly host the CUHK-KCL Annual Conference on Tax, Trade, and Investment Law on 10-11 September 2026 (Thursday and
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Newton: Tenure Mismatch Theory —Rethinking Federal Housing Subsidies Through Property Law
Deanna Newton (Pepperdine), Tenure Mismatch Theory: Rethinking Federal Housing Subsidies Through Property Law, 80 Tax L. Rev. ___ (2026): Researchers estimate that the United States has “3.8 million fewer homes” than are needed; yet, existing housing subsidies often fail to produce long-term affordable housing. This Article makes two novel contributions to the literature by positioning
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Eyal & Soled: Tax Bias in AI Gambling
Mirit Eyal (Alabama) & Jay A. Soled (Rutgers), Smart Bets, Unequal Odds: A Case Study of Tax Bias in AI Gambling: In the age of mobile wagering apps and algorithmic predictions, gambling has become ubiquitous, frictionless, and increasingly driven by artificial intelligence. This shift has been further accelerated by the emergence of AI-governed event-contract platforms
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SSRN Review & Roundup: Marks Reviews Georgakopoulos, Tarkington & Crawford’s Spousal Economic Abuse: Tax Complicity and Solutions
This week, Noah H. Marks (UNC) reviews a new article by Nicholas L. Georgakopoulos (Indiana), Margaret Tarkington (Indiana), and Bridget Crawford (Pace), Spousal Economic Abuse: Tax Complicity and Solutions (Feb. 11, 2026). The fact that the income tax system allows—and, indeed, encourages—married couples to file a joint tax return reporting pooled income is too often
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Hackney: Arts Tax Policy
Philip Hackney (Pittsburgh), Arts Tax Policy: Democracy or Plutocracy?, 60 Loy. L.A. L. Rev. (forthcoming 2026), U. of Pittsburgh Legal Studies Research Paper No. 2026-13, Available at SSRN: https://ssrn.com/abstract=6511360 The United States National Endowment for the Arts’ budget in 2024 was $207 million; in the same year the United States spent roughly between $2 and $3.35
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Cauble Presents “The Channels of Tax Law (Mis)Information” Today At Duke
Emily Cauble (Wisconsin) presents The Channels of Tax Law (Mis)Information at Duke today, as part of its Tax Policy Seminar hosted by Larry Zelenak: This Article sheds light on a pervasive phenomenon. In a variety of contexts, third parties provide information about tax law to taxpayers. The information provided by these third parties may guide the tax planning and
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Li Presents “State-Centrism in International Taxation: Rationale and Ramifications” Today At Toronto
Jinyan Li (York University) presents State-Centrism in International Taxation: Rationale and Ramifications at Toronto, as part of its James Hausman Tax Law and Policy Workshop Series hosted by Ben Alarie: The term “global” has recently been used in describing the nature of tax problems arising from the digitalization and globalization of the economy, the institutions and processes for developing solutions as
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Calderón Gómez: Charity’s Limits
Luis Calderón Gómez (Cardozo) has just posted a new article, “Charity’s Limits,” forthcoming in the Tax Law Review, on SSRN. From the abstract: Charity law’s most pressing contemporary problems are almost uniformly diagnosed by policymakers and scholars as isolated, doctrinal issues. This Article argues that this consensus is mistaken. Seemingly disparate developments—the increasing commercialization and
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Holden and Kisska-Schulze: The Taxable Future of College Sports
John T. Holden (Indiana) and Kathryn Kisska-Schulze (Clemson) have published The Taxable Future of College Sports, 77 Ala. L. Rev. 287 (2025). Here is the abstract: College sports are changing. Historically the National Collegiate Athletic Association (NCAA) exercised a strong arm to prohibit college athletes from receiving any form of compensation. Today, a power shift
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Wallace and Wells: The Past and Future of Taxing “Incomes”
Clint Wallace (South Carolina) & Bret Wells (Houston) have published The Past and Future of Taxing “Incomes”, 104 N.C. L. Rev. 1 (2025). Here is the abstract: For at least half a century, the text of the Sixteenth Amendment—“Congress shall have power to lay and collect taxes on incomes, from whatever source derived”—has been treated
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Christensen & Appleby: Taxing Indigenous Cultural Property
Grant Christensen (Alabama) and Andrew Appleby (Tennessee) have posted Taxing Indigenous Cultural Property, 52 BYU L. Rev. (forthcoming 2026). Here is the abstract: What is the value of something that cannot legally be sold? This question lies at the heart of a growing tension between federal tax policy and Indigenous rights. Although federal law prohibits
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Joondeph: Florida v. California and the Fair Apportionment of Corporate Income
Bradley W. Joondeph (Santa Clara, SSRN), Florida v. California and the Fair Apportionment of Corporate Income, 120 Tax Notes State 7 (Mar. 31, 2026): The Supreme Court is unlikely to grant Florida leave to file its complaint, in large part because Florida appears to lack standing to assert its claims in federal court. (It is unclear
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Eyal & Soled: Eliminate the Gambling Loss Tax Deduction
Mirit Eyal (Alabama) & Jay A. Soled Rutgers, Eliminate the Gambling Loss Tax Deduction, 190 Tax Notes Fed. 2029 (Mar. 23, 2026): To some, gambling is an exciting and joyful activity — an opportunity to beat the odds and prove one’s savviness or luck. To others, gambling is nothing less than a pure vice that,
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Soffe & Incerti: Anticipatory Effects of Corporate Tax Shaming
Trevor Incerti (U. Amsterdam, Dept. Pol. Econ.) & Raphaëlle Soffe (Inst. Fiscal Stud.), Anticipatory Effects of Corporate Tax Shaming: Evidence from the European Union, IFS Working Paper 26/19 (Mar. 5, 2026): Offshore wealth is estimated at 10% of global GDP. To curb tax avoidance, policymakers have adopted tax transparency reforms. We analyze anticipatory effects associated with