Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Cotti et al on E-Cigarette Taxation and Youth Vaping
Economists Chad D. Cotti, Dhaval M. Dave, Tessie Krishna, Erik T. Nesson, and Joseph J. Sabia have a new NBER working paper, “Do Informal Social Markets and Online Sellers Help Youths to Avoid E-Cigarette Taxation?” Here is the abstract: Youths who vape nicotine rarely make in-person purchases of e-cigarettes from a vendor but instead rely
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Korinek and Lockwood on Public Finance in the Age of AI
Anton Korinek and Lee Lockwood (both UVA) have a new NBER working paper, “Public Finance in the Age of AI: A Primer.” Here is the abstract: Transformative artificial intelligence (TAI) – machines capable of performing virtually all economically valuable work – may gradually erode the two main tax bases that underpin modern tax systems: labor
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TaxProf Op-Ed: Avi-Yonah on Learning Resources and Regulatory Taxation
This TaxProf Op-Ed on Learning Resources is by Reuven S. Avi-Yonah (Google Scholar), Irwin I. Cohn Professor of Law at the University of Michigan: Learning Resources and Regulatory Taxation Reuven S. Avi-Yonah On February 20, 2026, the Supreme Court issued its opinion in Learning Resources, Inc. v. Trump.[1] The Court held by a 6-3 majority
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Love: Taxing Complexity
Michael Love (Columbia), Taxing Complexity: Complex business structures have overwhelmed U.S. tax enforcement, leaving trillions of dollars of business activity beyond the reach of meaningful oversight. This article develops a new theoretical framework to understand and address the social costs of this complexity, identifying two distinct channels of harm. Not only does complexity shield a
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Dufour, Michaud & Smart: Salience and the Elasticity of Taxable Income: Evidence from Top-Bracket Tax Reforms
High-income taxpayers’ apparent responsiveness to tax rate changes may reflect this group’s tendency toward tax avoidance or greater ability to substitute leisure for labor. In a new working paper, Xavier Dufour, Pierre-Carl Michaud, and Michael G. Smart identify salience as another factor that may influence high-income taxpayers’ elasticities of taxable income. More below the fold.
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SSRN Review & Roundup: Elkins Reviews Fox, Liscow & Love’s How to Tax Business?
This week, David Elkins (Netanya; Google Scholar) reviews Edward G. Fox (Michigan; Google Scholar), Zachary D. Liscow (Yale; Google Scholar) & Michael Love (Columbia; Google Scholar), How to Tax Business? Economic Rents, Legibility, and the Corporate-Pass-Through Divide (2026): The dilemma of whether to tax income earned via an entity at the entity level or to
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Lederman & Lawsky: Constructing Deductions
Leandra Lederman (IU Maurer) & Sarah B. Lawsky (U. of Illinois), Constructing Deductions (February 17, 2026). Available at SSRN: https://ssrn.com/abstract=6258958 This Essay identifies drafting “building blocks” that are present in the Internal Revenue Code and that are used to construct many of the deductions available to individuals. The Essay represents these building blocks using mathematical formulas
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Kern Presents “Buy or D.I.Y.: Home Production and the Income Tax” At UCLA
Adam Kern (San Diego) presents Buy or D.I.Y.: Home Production and the Income Tax today at UCLA, as part of its Colloquium on Tax Policy and Public Finance: The income tax aspires to be comprehensive—a tax on “all income, from whatever source derived.” Yet every year, trillions of dollars of productive activity escapes taxation with
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Raskolnikov Presents “Formal Equality and Rawlsian Justice” At USC
Alex Raskolnikov (Columbia) presented “Formal Equality and Rawlsian Justice” at the USC Law Faculty workshop on February 19: Few political theories have been more scrutinized, criticized, valorized, and reinterpreted than John Rawls’s A Theory of Justice. Yet for all this attention, one of this theory’s core ideas has remained largely unrecognized by scholars and unacknowledged by
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Clarke Presents “What Made Income Taxes Possible” Today At Duke
Conor Clarke (Washington University) presents What Made Income Taxes Possible (co-authored with Edward Fox and Wojciech Kopczuk) at Duke today, as part of its Tax Policy Seminar hosted by Larry Zelenak: Why do governments impose taxes on “income” rather than (and in addition to) other things? Large literatures in economics, history, and political science answer
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Tax Podcasts Featuring Tax Profs
Perhaps this is old news for some, but I recently learned of two tax podcasts that feature tax professors. First, Tax Notes hosts a podcast called “Tax Notes Talk” (Apple, Spotify). This came across my radar because of a recent episode in which Jeremy Bearer-Friend (GWU) and Sarah Polcz (UC Davis) discuss their recent paper,
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Speck Publishes “Transforming Tax Expenditures”
Sloan Speck (Colorado) has published “Transforming Tax Expenditures” in the Columbia Business Law Review. Here is the abstract: For decades, reformers have advocated the repeal of tax expenditures–disguised government spending through special preferences in the Internal Revenue Code. And yet, tax expenditures persist, impairing federal tax receipts by more than $1.8 trillion in 2024. This
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Fox, Liscow, and Love on How To Tax Businesses
Edward Fox (Michigan), Zachary Liscow (Yale), and Michael Love (Columbia) have posted “How to Tax Business? Economic Rents, Legibility, and the Corporate-Pass-Through Divide” on SSRN. Here is the abstract: We reevaluate the choice between entity-level and pass-through taxation in light of two transformative U.S. trends. First, as business taxation converges toward a cash flow tax
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Blank Presents “Audit Guides & The Administrative State” Today at Boston College
Joshua Blank (UC Irvine) presents Audit Guides & The Administrative State (co-authored with Leigh Osofsky (UNC)) at Boston College today at 5pm ET as part of its Tax Policy Collaborative hosted by James Repetti and Diane Ring:
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Love Presents “Taxing Complexity” Today at San Diego
Michael Love (Columbia, SSRN) presents Taxing Complexity at San Diego today as part of its Tax Law Speaker Series.
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Morrow: The Income Tax as a Market Correction
Rebecca Morrow (Wake Forest), The Income Tax as a Market Correction, 76 UC Law SF L.J. 1373 (2025): I confess. As a tax professor, it has long hurt my feelings that economists label tax as a market distortion. My field is summed up as an impurity on the otherwise pristine complexion of the economist’s pure
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Brenzel-Weiss, Koeniger & Valladares-Estaban: Tax Incentives, Portfolio Choice, and Macroprudential Risks
Housing and housing affordability are hot political issues in the United States. Tax benefits for owner-occupied housing have played a role in this debate. But what are the potential collateral effects of these interventions into the residential housing market? In a new Center for Financial Studies working paper, three European researchers evaluate the effects of
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SSRN Review & Roundup: Marks Reviews Drumbl’s Poverty, Fresh Starts, and the Social Safety Net
This week, Noah H. Marks (UNC) reviews a new work by Michelle L. Drumbl (Washington & Lee), Poverty, Fresh Starts, and the Social Safety Net, 98 Temple L. Rev. 57 (2025): From the outside, the interface between federal income tax law and bankruptcy law (itself a combination of federal and state law) is a technical
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JOTWELL: Anatomy of a Shakedown: The Carried Interest Case
Charlene D. Luke (Florida), Anatomy of a Shakedown: The Carried Interest Case, JOTWELL (February 12, 2026) (reviewing Edward J. McCaffery & Darryll K. Jones, The Curiouser and Curiouser Case of Carried Interests, 66 Ariz. L. Rev. 357 (2024)). Edward J. McCaffery (USC) and Darryll K. Jones (FAMU) offer an engaging explanation for the lack of progress in closing the carried interest loophole
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UCLA’s Colloquium on Tax Policy and Public Finance (Spring 2026)
The UCLA Colloquium on Tax Policy and Public Finance is led by Professors Kirk Stark and Jason Oh:
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Brennan Presents “The Government’s Gift to Givers: Donating Appreciated Stock” Today at Toronto
Thomas J. Brennan (Harvard) presents The Government’s Gift to Givers: Donating Appreciated Stock at Toronto, as part of its James Hausman Tax Law and Policy Workshop Series hosted by Ben Alarie: Under Section 170(e), taxpayers can deduct appreciation without paying tax on this gain. This double benefit is well understood. Yet this Article frames the tax benefit somewhat
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Book Presents “Transformative Technology and Shortening the Statute of Limitations Applicable to Taxpayers” (co-authored with Jay Soled) Today At Georgia
Leslie Book (Villanova) presents Transformative Technology and Shortening the Statute of Limitations Applicable to Taxpayers (co-authored with Jay Soled) at Georgia today, as part of its Tax Policy Colloquium Series hosted by Assaf Harpaz: When it comes to submitting tax returns and paying taxes, most taxpayers understand the nature of their civic duties and do so dutifully, if not
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Hanlon, Shroff & Yoon: Taxes and Competition: Evidence from the Airline Industry
Michelle Hanlon (MIT Sloan), Nemit Shroff (MIT Sloan), and Rachel Yoon (Boston University – Questrom) have posted a new piece on SSRN titled “Taxes and Competition: Evidence from the Airline Industry,” forthcoming in the Journal of Accounting & Economics. Here is the abstract:
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Bagenstos: “Slush Funds” and Congress’s Power of the Purse
Sam Bagenstos (Michigan) has posted “Slush Funds” and Congress’s Power of the Purse on SSRN. Here is the abstract: If there’s one point on which everyone agrees in appropriations law, it’s that “slush funds” are bad. In the appropriations context, people tend to use the term to refer to financing mechanisms that enable the Executive
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Galle: How to Tax the Ultrarich
Brian D. Galle (UC Berkeley), How to Tax the Ultrarich (Roosevelt Institute Jan. 2026) (fact sheet): This report proposes a new tax, the Fair Share Tax (FAST), on very wealthy households. The FAST is imposed at sale like the current capital gains tax, but adds an interest-like extra tax on taxpayers who hold their assets