Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Virginia Tax Review Publishes New Issue
The Virginia Tax Review has published Vol. 43, No. 3 (Spring 2024): Steven M. Sheffrin (Tulane; Google Scholar), Disparate Impact in Taxation Meets Disparate Impact Jurisprudence: Burdens vs. Barriers, 43 Va. Tax Rev. 331 (2024) Sarah B. Lawsky (Northwestern; Google Scholar), Reasoning with Formalized Statutes: The Case of Capital Gains and Losses, 43 Va. Tax Rev. 361 (2024) Michael
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Virginia Tax Review Publishes New Issue
The Virginia Tax Review has published Vol. 43, No. 3 (Spring 2024): Steven M. Sheffrin (Tulane; Google Scholar), Disparate Impact in Taxation Meets Disparate Impact Jurisprudence: Burdens vs. Barriers, 43 Va. Tax Rev. 331 (2024) Sarah B. Lawsky (Northwestern; Google Scholar), Reasoning with Formalized Statutes: The Case of Capital Gains and Losses, 43 Va. Tax Rev. 361 (2024) Michael
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Taxation Of Income From Cross-Border Services: A Global Normative And Enforcement Approach To Legal Issues And Policy Options
Pasquale Pistone (IBFD, Vienna University; Google Scholar), Sergio Messina (IBFD), Alessandro Turina (IBFD) & Craig West (IBFD, University of Cape Town; Google Scholar), Taxation of Income from Cross-Border Services: A Global Normative and Enforcement Approach to Legal Issues and Policy Options: The harmful effect of international juridical double taxation on cross-border services has been acknowledged
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Taxation Of Income From Cross-Border Services: A Global Normative And Enforcement Approach To Legal Issues And Policy Options
Pasquale Pistone (IBFD, Vienna University; Google Scholar), Sergio Messina (IBFD), Alessandro Turina (IBFD) & Craig West (IBFD, University of Cape Town; Google Scholar), Taxation of Income from Cross-Border Services: A Global Normative and Enforcement Approach to Legal Issues and Policy Options: The harmful effect of international juridical double taxation on cross-border services has been acknowledged
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Schwidetzky: Reforming Self-Employment Taxes
Walter D. Schwidetzky (Baltimore), Reforming Self-Employment Taxes, 185 Tax Notes Fed. 461 (Oct. 21, 2024): In this report, Schwidetzky proposes reforms to address tax avoidance and other problems with self-employment tax. IntroductionTaxpayers for decades have been seeking ways to avoid self-employment taxes. By self-employment taxes, I mean the taxes imposed by section 1401, which are
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Schwidetzky: Reforming Self-Employment Taxes
Walter D. Schwidetzky (Baltimore), Reforming Self-Employment Taxes, 185 Tax Notes Fed. 461 (Oct. 21, 2024): In this report, Schwidetzky proposes reforms to address tax avoidance and other problems with self-employment tax. IntroductionTaxpayers for decades have been seeking ways to avoid self-employment taxes. By self-employment taxes, I mean the taxes imposed by section 1401, which are
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Why Is University Housing Tax-Exempt?
Hacibey Çatalbaşoğlu (J.D. 2024, NYU), Note, Why Is University Housing Tax-Exempt?, 99 N.Y.U. L. Rev. 1721 (2024): In this Note, I challenge three dominant theories behind property tax exemptions for university housing—the “Quid-Pro-Quo,” “Sovereignty,” and, what I call, “Oxbridge” theories—and propose that only undergrad housing should be taxexempt. My proposal would recognize the unique educational
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Why Is University Housing Tax-Exempt?
Hacibey Çatalbaşoğlu (J.D. 2024, NYU), Note, Why Is University Housing Tax-Exempt?, 99 N.Y.U. L. Rev. 1721 (2024): In this Note, I challenge three dominant theories behind property tax exemptions for university housing—the “Quid-Pro-Quo,” “Sovereignty,” and, what I call, “Oxbridge” theories—and propose that only undergrad housing should be taxexempt. My proposal would recognize the unique educational
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Artful Imbalance: How the US Tax Code And State Trust Laws Enable The Growth Of Inequality Through High-Value Art Collections
Mimi Strauss (J.D. 2024, Brooklyn), Note, Artful Imbalance: How the US Tax Code and State Trust Laws Enable the Growth of Inequality Through High-Value Art Collections, 89 Brook. L. Rev. 681 (2024): The United States has become the leading jurisdiction for those who wish to buy and store high-value art and NFTs, pay as few
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Artful Imbalance: How the US Tax Code And State Trust Laws Enable The Growth Of Inequality Through High-Value Art Collections
Mimi Strauss (J.D. 2024, Brooklyn), Note, Artful Imbalance: How the US Tax Code and State Trust Laws Enable the Growth of Inequality Through High-Value Art Collections, 89 Brook. L. Rev. 681 (2024): The United States has become the leading jurisdiction for those who wish to buy and store high-value art and NFTs, pay as few
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Mazur & Thimmesch: Transforming Tax Communications With Large Language Models
Orly Mazur (SMU; Google Scholar) & Adam Thimmesch (Nebraska; Google Scholar), Transforming Tax Communications With Large Language Models, 185 Tax Notes Fed. 757 (Oct. 28, 2024): In this installment of Academic Perspectives on SALT, Mazur and Thimmesch explore how to improve the efficiency and equity of tax administration through the strategic use of large language
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Mazur & Thimmesch: Transforming Tax Communications With Large Language Models
Orly Mazur (SMU; Google Scholar) & Adam Thimmesch (Nebraska; Google Scholar), Transforming Tax Communications With Large Language Models, 185 Tax Notes Fed. 757 (Oct. 28, 2024): In this installment of Academic Perspectives on SALT, Mazur and Thimmesch explore how to improve the efficiency and equity of tax administration through the strategic use of large language
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Origination And Original Meaning: Reviving The Origination Clause To Restrain The Administrative State
Jake Settle (J.D. 2025, George Mason), Comment, Origination and Original Meaning: Reviving the Origination Clause to Restrain the Administrative State, 31 Geo. Mason L. Rev. 697 (2024) There is a disturbing trend of federal agencies assessing fees to be paid by taxpayers via administrative rulemaking. This unconstitutional arrangement leaves Americans in danger of taxation without
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Origination And Original Meaning: Reviving The Origination Clause To Restrain The Administrative State
Jake Settle (J.D. 2025, George Mason), Comment, Origination and Original Meaning: Reviving the Origination Clause to Restrain the Administrative State, 31 Geo. Mason L. Rev. 697 (2024) There is a disturbing trend of federal agencies assessing fees to be paid by taxpayers via administrative rulemaking. This unconstitutional arrangement leaves Americans in danger of taxation without
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Lesson From The Tax Court: FBAR Penalties Are Not Tax Penalties … Thank Goodness
We often talk about “the IRS” as if it were a person (or animal!). Or we talk about the “Treasury Department” doing this or that. But agencies are legal fictions. They do not exist. The actual work is done by actual people. Thus when you read statutes that Congress writes, you see that Congress generally
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The Top Five New Tax Papers
There is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new paper debuting on the list at #5. [1007 Downloads] Federal Tax Procedure (2024 Practitioner Ed.), by John Townsend (Houston; Google Scholar) [905 Downloads] What is Tax Fairness?, by Rita de la Feria (Leeds; Google
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The Top Five New Tax Papers
There is a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with a new paper debuting on the list at #5. [1007 Downloads] Federal Tax Procedure (2024 Practitioner Ed.), by John Townsend (Houston; Google Scholar) [905 Downloads] What is Tax Fairness?, by Rita de la Feria (Leeds; Google
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 77, No. 4 (Summer 2024): Hayes Holderness (Richmond), Self-Policing Through Retaliatory Taxation, 77 Tax Law. 715 (2024) Adam B. Thimmesch (Nebraska; Google Scholar), A Future for the State Corporate Income Tax, 77 Tax Law. 761 (2024):
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 77, No. 4 (Summer 2024): Hayes Holderness (Richmond), Self-Policing Through Retaliatory Taxation, 77 Tax Law. 715 (2024) Adam B. Thimmesch (Nebraska; Google Scholar), A Future for the State Corporate Income Tax, 77 Tax Law. 761 (2024):
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Florida Symposium: Moore, Loper Bright, Corner Post, And The Future Of The Federal Tax System
The University of Florida Levin College of Law hosts the Florida Tax Review Symposium on Moore, Loper Bright, Corner Post, and the Future of the Federal Tax System today and tomorrow (agenda): Friday, November 1: 9:15 – 11:15 AM (zoom) Reuven Avi-Yonah (Michigan; Google Scholar) & Muskan Sharma (Michigan), Containing the Blast Radius: Can Congress
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Florida Symposium: Moore, Loper Bright, Corner Post, And The Future Of The Federal Tax System
The University of Florida Levin College of Law hosts the Florida Tax Review Symposium on Moore, Loper Bright, Corner Post, and the Future of the Federal Tax System today and tomorrow (agenda): Friday, November 1: 9:15 – 11:15 AM (zoom) Reuven Avi-Yonah (Michigan; Google Scholar) & Muskan Sharma (Michigan), Containing the Blast Radius: Can Congress
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Aprill & Mayer: 21st Century Churches And Federal Tax Law
Ellen P. Aprill (Loyola-L.A.; Google Scholar) & Lloyd Hitoshi Mayer (Notre Dame; Google Scholar), 21st Century Churches and Federal Tax Law, 2024 U. Ill. L. Rev. 939: Federal tax treatment matters to churches, the term the IRS uses for all types of religious congregations, including synagogues, mosques, and temples. The federal tax provisions most significant
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Aprill & Mayer: 21st Century Churches And Federal Tax Law
Ellen P. Aprill (Loyola-L.A.; Google Scholar) & Lloyd Hitoshi Mayer (Notre Dame; Google Scholar), 21st Century Churches and Federal Tax Law, 2024 U. Ill. L. Rev. 939: Federal tax treatment matters to churches, the term the IRS uses for all types of religious congregations, including synagogues, mosques, and temples. The federal tax provisions most significant
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International Tax Implications For Private Equity Investments
Young Ran (Christine) Kim (Cardozo; Google Scholar), International Tax Implications for Private Equity Investments, in Research Handbook on the Structure of Private Equity and Venture Capital (Brian Broughman (Vanderbilt; Google Scholar) & Elisabeth de Fontenay (Duke; Google Scholar) eds., forthcoming 2025). : Private equity funds (PEFs) have continuously grown over the last couple of decades, making