Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Delmotte: Equality Before Tax Law
Charles Delmotte (Michigan State) has published “Equality Before Tax Law” in the Washington & Lee Law Review. Here is the abstract: The income tax code is riddled with exceptions—exclusions, rate preferences, and deductions—that reduce tax burdens for dominant majorities and powerful interest groups. These carveouts now amount to an astonishing $1.9 trillion, equivalent to seventy-five…
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Dynan, Elmendorf, and Gullo on Federal Discretionary Spending
Karen Dynan (Harvard), Douglas Elmendorf (Harvard), and Theresa Gullo (Arbroath Associates) have a new NBER working paper, “The Federal Government’s Discretionary Spending” (May 2026). Here is the abstract: This paper examines federal discretionary spending, including its place in the overall budget, its composition, and the economic and political forces shaping its size. Both defense and…
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Zhang: The Forgotten Attribution Power
Alex Zhang (Emory), The Forgotten Attribution Power, 135 Yale L.J. 923 (2026): Economic inequality stands at record levels, and constitutional law haunts egalitarian reform. In 2024, the Supreme Court decided the latest contest. Moore v. United States rebuffed an attempt to sharply limit the federal taxing power, as a razor-thin majority upheld Congress’s attribution of foreign…
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Faccio & Manfredonia: Taxes and Financial Distress
Mara Faccio (Purdue) & Stephano Manfredonia (Fordham), Taxes and Financial Distress: Evidence from Establishment-Level Data, NBER Working Paper No. 35134 (Apr. 2026):
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SSRN Review & Roundup: Marks Reviews Lawsky’s Limiting Inconsistencies in Legal Languages
This week, Noah H. Marks (UNC) reviews a new article by Sarah B. Lawsky (Illinois), Limiting Inconsistencies in Legal Languages, 28 Vanderbilt J. Ent. & Tech. L. 765 (2026). Tax practitioners, professors, and students are all too aware that the Code, despite its interconnectedness and intricacies, is far from a logically consistent, unified whole. Overlapping…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 43 (May 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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Columbia Tax Policy Conference
Columbia Law School: Tax Policy Conference Sponsored by The Charles E. Gerber Transactional Studies Center and Davis Polk & Wardwell (May 28-29, 2026):
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Eleventh Annual Texas Tax Faculty Workshop
On May 19, Baylor Law School hosted the Eleventh Annual Texas Tax Faculty Workshop: Also in attendance were Eric Reis (UNT Dallas) and Rita Julien (Houston).
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Harpaz Presents “Towards a Theory of Tax Sovereignty” at UNLV
Assaf Harpaz (Georgia) will be presenting his article “Toward a Theory of Tax Sovereignty” at the National Business Law Scholars Conference 2026, as part of the panel on Tax Theory & Policy. The conference is hosted by the William S. Boyd School of Law at the University of Nevada, Las Vegas. Here’s the abstract of…
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Angrist et al on University Endowment Taxation and Scientific Progress
Joshua Angrist (MIT), Marc Diederichs (Passau) & Glenn Ellison (MIT) have a new NBER working paper, “Will The University Endowment Tax Slow Scientific Progress? Evidence from Elite Economics PhD Programs.” Here is the abstract: The 2025 university endowment tax hike and other sources of financial pressure may lead the schools that train the most prolific…
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Boll, Saez, and Zucman on California Billionaires
Jasper Boll (Paris School of Economics), Emmanuel Saez (Berkeley), and Gabriel Zucman (PSE and Berkeley) have a new NBER working paper, “California Billionaires: Wealth, Taxes, and Wealth Tax Revenue Estimates.” Here is the abstract: This paper documents the wealth of California’s billionaires and the taxes they pay. California billionaires’ wealth exceeds $2 trillion today, the…
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Avi-Yonah on the Revival of Economic Substance
Reuven Avi-Yonah (Michigan), “Liberty Global and the Revival of Economic Substance” (Tax Notes, May 25, 2026): On April 21 the Tenth Circuit issued its long-awaited opinion in Liberty Global. By a 2-1 majority, the panel upheld the decision of the district court that a tax shelter used by Liberty Global had to be disregarded under…
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Pittsburgh Tax Review | ATPI Symposium: Gender & Tax
The Pittsburgh Tax Review has published Vol. 23, No. 1 (2025): ATPI Symposium on Gender & Tax, 23 Pitt. Tax Rev. 1-281 (2025):
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IFS Working Paper: Discretion Versus Algorithms
Justine Knebelmann, Victor Pouliquen & Bassirou Sarr, Discretion Versus Algorithms: Bureaucrats, Tax Equity and Acceptability, Inst. Fisc. Stud. Working Paper 26/34 (May 11, 2026):
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SSRN Review & Roundup: Harpaz Reviews Pratt’s Aligning Reparations and Taxation
This week, Assaf Harpaz (Georgia; Google Scholar) reviews a new work by Katherine Pratt (Loyola LA; Google Scholar), Aligning Reparations and Taxation, Wm. & Mary J. Race, Gender & Soc. Just. (forthcoming). In Aligning Reparations and Taxation, the author makes an exceptional contribution to the tax literature by examining the nontaxation of reparation remedies. Absent…
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Bloomberg: “Oregon Voters Reject Gasoline Tax Increase as Pump Prices Soar”
Bloomberg, Oregon Voters Reject Gasoline Tax Increase as Pump Prices Soar: Oregon voters repealed a 6-cent per gallon fuel tax increase enacted last year to shore up the state’s transportation budget, throwing long-term funding into uncertainty. About 83% of voters rejected the tax increase, which was passed by the Democrat-controlled legislature in a special session…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 44 (May 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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Gamage & Brooks: The Federal Taxing Power in Its New Constitutional Era
David Gamage (Missouri) and John Brooks (Fordham) have a new piece on SSRN, forthcoming in the Tax Law Review, “The Federal Taxing Power in Its New Constitutional Era.” Here is the abstract: A paradox now sits at the heart of constitutional tax law. Recent jurisprudence culminating in Moore v. United States has presumably revived the…
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Avi-Yonah: Liberty Global and the Revival of Economic Substance
In Tax Notes, Reuven Avi-Yonah (Michigan) has a new piece, “Liberty Global and the Revival of Economic Substance.” From the piece: This decision [Liberty Global, Inc. v. United States] is the third victory of the government in [economic substance doctrine (ESD)] cases, following Patel and Otay. But it is the most significant because it strikes…
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Herzfeld: Inverting the Tax Landscape
Mindy Herzfeld (Florida), “Inverting the Tax Landscape: Domestications” (Tax Notes, May 18, 2026): Cast your mind back 10 years (if you can) to the hottest cross-border tax and mergers and acquisitions strategy of the day: inversions. That term generally encompassed both single U.S. companies reincorporating overseas into tax-favorable jurisdictions and mergers between U.S. and foreign…
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Estimating the Present Value of R&D Tax Benefits
Brandon Pecoraro (Joint Committee on Taxation) et al, “Estimating the Present Value of R&D Tax Benefits in the United States” (NBER May 2026): Using a panel of confidential corporate tax returns, we provide the first direct estimates of the realized present value of corporate tax benefits from R&D credits and deductions in the United States.…
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Viswanathan: Toward Issuer-Based Certification of Qualified Small Business Stock
Manoj Viswanathan (UC Law SF), Toward Issuer-Based Certification of Qualified Small Business Stock, 191 Tax Notes Fed. 369 (Apr. 20, 2026): The qualified small business stock (QSBS) exclusion under section 1202 allows shareholders of certain startups to exclude from income tax the greater of $10 million ($15 million for stock acquired after July 4, 2025) or 10…
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Gale et al.: One Big Beautiful Bill? A Preliminary Assessment
William G. Gale (Brookings Inst.), Benjamin Page (Urban-Brookings Tax Pol’y Ctr.), Elena Patel (Brookings Inst.) & Joseph W. Rosenberg (Urban-Brookings Tax Pol’y Ctr.), One Big Beautiful Bill? A Preliminary Assessment (Mar. 23, 2026):
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SSRN Review & Roundup: Saito Reviews Gamage & Shanske’s Against Doctrinal Siloing
This week, Blaine Saito (Ohio State, Google Scholar) reviews a new work by David Gamage (Missouri, Google Scholar) and Darien Shanske (UC Davis, Google Scholar), Against Doctrinal Siloing: Harmonizing Fiscal Federalism and the U.S. Constitution, 103 Wash U. L. Rev. _ (forthcoming 2026). Fiscal federalism is embedded within the U.S. constitutional structure dating back to the founders. Over…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 41 (May 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron: