Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Inequality: “Who Pays Federal Income Taxes? The Rich, But Not Nearly as Much as They Should — or Once Did”
Inequality, Who Pays Federal Income Taxes? The Rich, But Not Nearly as Much as They Should — or Once Did: A recent analysis from the Tax Foundation argues that the U.S. federal income tax system remains solidly progressive. Citing new IRS data for tax year 2023, the group is emphasizing that high-income taxpayers pay the…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 40 (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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Thorndike: When Congress Reformed the IRS Without Starving It
Joseph Thorndike, “When Congress Reformed the IRS Without Starving It” (Tax Notes, May 11, 2026): On a hot summer day in late July 1953, employees of the IRS began walking the streets of Boston, ringing doorbells and putting two simple questions to anyone who answered: Have you filed your 1952 return? Can you prove it? A yes…
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Avi-Yonah: Are Wealth Taxes and Mark-to-Market Income Taxes Constitutional?
Reuven Avi-Yonah (Michigan) has a new column in Tax Notes, “Are Wealth Taxes and Mark-to-Market Income Taxes Constitutional?” Here is the introduction: In Moore v. United States, the Supreme Court avoided the question of whether a wealth tax or a tax on unrealized income is constitutional. The majority held that as long as income is realized by…
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Givati: Income and Preferences for International Redistribution
Yehonatan Givati (Hebrew University of Jerusalem) has published “Income and Preferences for International Redistribution: Theory and Evidence” in the Journal of Empirical Legal Studies. Here is the abstract: How do preferences for international redistribution vary with income across countries? And within countries, are poor people more or less likely than rich people to support international…
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Beyond Homeowner Preference: Three Frames for Housing Taxation
Yijie Chen (J.D. 2027, Indiana-Maurer) & Stephanie Hunter McMahon (Indiana-Maurer), Beyond Homeowner Preference: Three Frames for Housing Taxation, 191 Tax Notes Fed. 95 (Apr. 13, 2026): Much of the existing discussion of housing’s tax advantages tends to emphasize a familiar subset of homeowner-facing provisions, which can make the system look like a simple story of…
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Burke: Active Limited Partners Flunk Functional Test
Karen C. Burke (Florida), Active Limited Partners Flunk Functional Test, Tax Law. (2026):
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SSRN Review & Roundup: Speck Reviews Galle’s Consumption Taxes and the Constitution
This week, Sloan Speck (Google Scholar) reviews a new work by Brian D. Galle (UC Berkeley, Google Scholar), Consumption Taxes and the Constitution, 103 Wash. U. L. Rev. _ (forthcoming 2026). The Supreme Court’s decision in Moore v. United States breathed new life into long-dormant constitutional questions about tax law’s realization doctrine. These questions not…
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Bloomberg: “IRS Previews Deal to Shrink Conservation Easement Backlog, Abuse”
Bloomberg, IRS Previews Deal to Shrink Conservation Easement Backlog, Abuse: The IRS said it will soon release details on a time-limited settlement offer for conservation easement cases as it tries to ax the backlog of litigation in the US Tax Court. Aggressive tax planners have for years assembled investors to claim tax deductions for charitable…
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Jurow Kleiman: “Progressive User Fees”
Ariel Jurow Kleiman (USC; Google Scholar), Progressive User Fees, 101 Tax L. Rev. 137 (2026): Since the Tax Revolt of the 1970s, cash-strapped state and local governments have increasingly relied on user fees to pay for public programs. Scholars attuned to city budgets have raised alarms about these fees: They undermine government’s redistributive role, impose regressive costs,…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 38 (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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National Tax Journal Publishes New Issue
The National Tax Journal has published volume 79, number 1 (March 2026): Michael Love (Columbia), Where in the World Does Partnership Income Go? Evidence of a Growing Use of Tax Havens, 79 Nat’l Tax J. 7 (2026). Geoffrey Gee (Treasury), Jacob Goldin (Chicago), Joseph Gray-Hancuch (Treasury), Ithai Z. Lurie (Treasury), and Vedant Vohra (UCSD Economics), The Claiming…
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Holter et al on Progressivity and Optimal Household Taxation
Hans Holter (Delaware) and co-authors have a new NBER working paper, “Till the IRS Do Us Part: (Optimal) Taxation of Households.” Here is the abstract: This paper argues that a progressive tax system combined with individual taxation of married couples can generate more revenue than the current household-based U.S. system, especially when the extra revenues…
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Mehrotra Reviews Campbell’s “Taxation and Resentment”
Ajay K. Mehrotra (Northwestern) has published a Lawfare review essay on a new book by Andrea Louise Campbell (MIT Political Science), Taxation and Resentment: Race, Party, and Class in American Tax Attitudes (2025). From the review: Since the 1980s, tax cuts have been a cornerstone of national Republican economic policy. The 1970s property tax revolts began…
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Galle: Consumption Taxes and the Constitution
Brian D. Galle (UC-Berkeley), Consumption Taxes and the Constitution, 103 Wash. Univ. L. Rev. ___ (2026): In the aftermath of Moore v. United States, there has been a modest rise in interest in U.S. consumption taxes, not only for revenue raising but as a response to inequality. This Essay argues that these consumption tax proposals are…
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Love: Where in the World Does Partnership Income Go?
Michael Love (Columbia), Where in the World Does Partnership Income Go? Evidence of a Growing Use of Tax Havens, 79 Nat’l Tax J. 7 (2026):
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SSRN Review & Roundup: Gordon Reviews Hemel & Kern’s Separation of Bases and the Fiscal Constitution
This week, Jeff Gordon (Vanderbilt, Google Scholar) reviews Daniel Hemel (NYU, Google Scholar) and Adam Kern (University of San Diego, Google Scholar), Separation of Bases and the Fiscal Constitution, 105 Tex. L. Rev. _ (forthcoming 2027). Daniel Hemel and Adam Kern have written an ambitious article that aims to reshape our understanding of the relationship…
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Gordon: “Carbon Shelters: Carbon Accounting as Tax Law”
Jeff Gordon (Vanderbilt), Carbon Shelters: Carbon Accounting as Tax Law (forthcoming in California Law Review 2026): This Article provides the first comprehensive account of the reconstruction of energy tax law that occurred under the Biden administration. In the past, federal energy policy offered carrots and sticks aimed selectively at specific sources of emissions (e.g. power…
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Clausing: Lessons from Three Global Collective Action Problems
Kimberly A. Clausing (UCLA), Lessons from Three Global Collective Action Problems, 46 Va. Tax Rev. ___ (2026): This paper compares three global collective action problems: those involving climate change, international trade, and international taxation. First, each problem is assessed in terms of fundamental elements that stymie global collective action: concentrated interests that deter action in…
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Camp: The New Forever Rule for Tax Record Retention
Bryan T. Camp (Texas Tech), The New Forever Rule for Record Retention, 190 Tax Notes Fed. 2183 (Mar. 30, 2026): W]hen people ask me how long they must keep their tax records, they are in effect asking how long they will run the risk of audit. My traditional answer had been three years. That is…
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Jensen & Weigel: No Taxation Without Administration
Anders D. Jensen (Harvard, Kennedy Sch.) & Jonathan L. Weigel (UC Berkeley, Haas Sch. Bus.), No Taxation Without Administration: Bringing the State Back into the Public Finance of Developing Countries, 64 J. Econ. Lit. 246 (2026): The empirical economics literature on taxation in developing countries has centered on the importance of third-party information for enforcement. Yet,…
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SSRN Review & Roundup: Eyal Reviews Bank’s High Rates and Low Taxes
This week, Mirit Eyal (Alabama; Google Scholar) reviews Steven A. Bank (UCLA; SSRN), Introduction, High Rates and Low Taxes: Tax Dodging in Mid-Century America (Cambridge University Press 2026). A word of full disclosure before we begin. Steven Bank was my doctoral advisor and mentor, and it is entirely possible, indeed more than likely, that I…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 30 (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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Hemel & Kern: Separation of Bases and the Fiscal Constitution
Daniel Hemel (NYU) and Adam Kern (San Diego) have a new paper just posted on SSRN and forthcoming in the Texas Law Review, “Separation of Bases and the Fiscal Constitution.” Here is the abstract: A central concern of constitutional law and theory is the question of tax assignment: In a multilevel system of government, who…
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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: