Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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Tax Obedience During COVID Times: A Role-Play Illustrating Tax Policy Dilemmas
Nellie Munin (Zefat Academic College; Google Scholar) & Yael Efron (Zefat Academic College; Google Scholar), Tax Obedience During COVID Times: A Role-Play Illustrating Tax Policy Dilemmas, 75 Wash. U. J.L. & Pol’y 189 (2024): Professors at Zefat Academic College (ZAC) School of Law in Israel are engaging students with innovating pedagogical techniques in tax law
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Why 501(c)(3) Tax-Exempt Status Does Not Count As Federal Financial Assistance Under Title IX
William A. Jordan (J.D. 2024, Iowa), Note, Why 501(c)(3) Tax-Exempt Status Does Not Count as Federal Financial Assistance Under Title IX, 109 Iowa L. Rev. 1807 (2024): Two federal district courts in Maryland and California have ruled that private schools are subject to Title IX of the Education Amendments of 1972 because their tax-exempt status
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Why 501(c)(3) Tax-Exempt Status Does Not Count As Federal Financial Assistance Under Title IX
William A. Jordan (J.D. 2024, Iowa), Note, Why 501(c)(3) Tax-Exempt Status Does Not Count as Federal Financial Assistance Under Title IX, 109 Iowa L. Rev. 1807 (2024): Two federal district courts in Maryland and California have ruled that private schools are subject to Title IX of the Education Amendments of 1972 because their tax-exempt status
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Taxing “Borrow” In “Buy/Borrow/Die”
Colin J. Heath (J.D. 2024, NYU), Note, Taxing "Borrow" in "Buy/Borrow/Die", 99 N.Y.U. L. Rev. 717 (2024): The United States federal income tax contains a flaw: Because it reaches capital gains only after a “realization” event, it permits owners of highly appreciated assets to defer their tax liability by holding them and refusing to sell.
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Taxing “Borrow” In “Buy/Borrow/Die”
Colin J. Heath (J.D. 2024, NYU), Note, Taxing "Borrow" in "Buy/Borrow/Die", 99 N.Y.U. L. Rev. 717 (2024): The United States federal income tax contains a flaw: Because it reaches capital gains only after a “realization” event, it permits owners of highly appreciated assets to defer their tax liability by holding them and refusing to sell.
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Jones: Stochastic Terrorism, Speech Incantations, And Federal Tax Exemption
Darryll Keith Jones (Florida A&M), Stochastic Terrorism, Speech Incantations, and Federal Tax Exemption, 54 N.M. L. Rev. 69 (2024): Stochastic terrorists demonize and dehumanize groups of people through propaganda to incite “lone wolf” violence against those groups. Their demonization and dehumanization is explicit, but their solicitation of murder is implicit and sufficiently ambiguous that most
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Jones: Stochastic Terrorism, Speech Incantations, And Federal Tax Exemption
Darryll Keith Jones (Florida A&M), Stochastic Terrorism, Speech Incantations, and Federal Tax Exemption, 54 N.M. L. Rev. 69 (2024): Stochastic terrorists demonize and dehumanize groups of people through propaganda to incite “lone wolf” violence against those groups. Their demonization and dehumanization is explicit, but their solicitation of murder is implicit and sufficiently ambiguous that most
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Harpaz: Can U.N. Framework Tax Convention Bridge The North-South Divide?
Assaf Harpaz (Georgia; Google Scholar), The U.N. Framework Tax Convention: Can It Bridge the North-South Divide?, 115 Tax Notes Int’l 1779 (Sept. 16, 2024): The United Nations recently concluded the second session of negotiations on terms of reference for a framework convention on international tax cooperation. The framework convention presents an opportunity to multilaterally address
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Harpaz: Can U.N. Framework Tax Convention Bridge The North-South Divide?
Assaf Harpaz (Georgia; Google Scholar), The U.N. Framework Tax Convention: Can It Bridge the North-South Divide?, 115 Tax Notes Int’l 1779 (Sept. 16, 2024): The United Nations recently concluded the second session of negotiations on terms of reference for a framework convention on international tax cooperation. The framework convention presents an opportunity to multilaterally address
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Kim & Shanske: State Digital Services Taxes—A Good And Permissible Idea
Young Ran (Christine) Kim (Cardozo; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), State Digital Services Taxes: A Good and Permissible Idea (Despite What You Might Have Heard), 98 Notre Dame L. Rev. 741 (2022): Tax systems have been struggling to adapt to the digitalization of the economy. At the center of the struggles is
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Kim & Shanske: State Digital Services Taxes—A Good And Permissible Idea
Young Ran (Christine) Kim (Cardozo; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), State Digital Services Taxes: A Good and Permissible Idea (Despite What You Might Have Heard), 98 Notre Dame L. Rev. 741 (2022): Tax systems have been struggling to adapt to the digitalization of the economy. At the center of the struggles is
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Thimmesch: A Future For The State Corporate Income Tax
Adam B. Thimmesch (Nebraska; Google Scholar), A Future for the State Corporate Income Tax, 78 Tax Law. __ (2024): The state corporate income tax is a flawed tax instrument, but calls to eliminate that tax should be reconsidered. To start, a variety of legal and practical limitations on states’ taxing powers prevent states from offsetting
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Thimmesch: A Future For The State Corporate Income Tax
Adam B. Thimmesch (Nebraska; Google Scholar), A Future for the State Corporate Income Tax, 78 Tax Law. __ (2024): The state corporate income tax is a flawed tax instrument, but calls to eliminate that tax should be reconsidered. To start, a variety of legal and practical limitations on states’ taxing powers prevent states from offsetting
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Populism And Taxation
Doron Narotzki (Akron; Google Scholar) & Tamir Shanan (College of Management; Google Scholar), Populism and Taxation, 33 S. Cal. Interdisc. L.J. 365 (2023): This Article explores the presence of populism in the field of law, specifically focusing on U.S. federal taxation. While discussions on populism typically revolve around politics, this Article highlights its occurrence in
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Populism And Taxation
Doron Narotzki (Akron; Google Scholar) & Tamir Shanan (College of Management; Google Scholar), Populism and Taxation, 33 S. Cal. Interdisc. L.J. 365 (2023): This Article explores the presence of populism in the field of law, specifically focusing on U.S. federal taxation. While discussions on populism typically revolve around politics, this Article highlights its occurrence in
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Hayashi: Christianity And The Liberal(ish) Income Tax
Andrew T. Hayashi (Virginia; Google Scholar), Christianity and the Liberal(ish) Income Tax, 38 Notre Dame J.L. Ethics & Pub. Pol’y 129 (2024): Liberalism is back on its heels, pushed there by political movements in the United States and Europe and by the critiques of legal scholars and political theorists. Some of the most vigorous recent
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Hayashi: Christianity And The Liberal(ish) Income Tax
Andrew T. Hayashi (Virginia; Google Scholar), Christianity and the Liberal(ish) Income Tax, 38 Notre Dame J.L. Ethics & Pub. Pol’y 129 (2024): Liberalism is back on its heels, pushed there by political movements in the United States and Europe and by the critiques of legal scholars and political theorists. Some of the most vigorous recent
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The Top Five New Tax Papers
This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list. [939 Downloads] Federal Tax Procedure (2024 Practitioner Ed.), by John Townsend (Houston; Google Scholar) [836 Downloads] What is Tax Fairness?, by Rita de la Feria (Leeds; Google Scholar) [458 Downloads] Reforming the Taxation of Life Insurance, by
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The Top Five New Tax Papers
This week's list of the Top 5 Recent Tax Paper Downloads is the same as last week's list. [939 Downloads] Federal Tax Procedure (2024 Practitioner Ed.), by John Townsend (Houston; Google Scholar) [836 Downloads] What is Tax Fairness?, by Rita de la Feria (Leeds; Google Scholar) [458 Downloads] Reforming the Taxation of Life Insurance, by
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Soled: The Nation’s Transfer Tax Regime And The Tax Gap
Jay A. Soled (Rutgers; Google Scholar), The Nation's Transfer Tax Regime and the Tax Gap, 76 Okla. L. Rev. 699 (2024): For over a century, the nation’s transfer tax regime, comprised of the gift, estate, and generation-skipping transfer taxes, has played a pivotal role in curbing inherited wealth while simultaneously raising much-needed revenue. But for
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Soled: The Nation’s Transfer Tax Regime And The Tax Gap
Jay A. Soled (Rutgers; Google Scholar), The Nation's Transfer Tax Regime and the Tax Gap, 76 Okla. L. Rev. 699 (2024): For over a century, the nation’s transfer tax regime, comprised of the gift, estate, and generation-skipping transfer taxes, has played a pivotal role in curbing inherited wealth while simultaneously raising much-needed revenue. But for
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Speck’s The Realization Rule As A Legal Standard
This week, David Elkins (Netanya, Google Scholar) reviews Sloan G. Speck (Colorado; Google Scholar), The Realization Rule as a Legal Standard, 16 Colum. J. Tax L. ___ (2024): Moore v. United States, decided by the Supreme Court in June of this year, reignited discussion about the concept of realization in the income tax. While statutory law
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Speck’s The Realization Rule As A Legal Standard
This week, David Elkins (Netanya, Google Scholar) reviews Sloan G. Speck (Colorado; Google Scholar), The Realization Rule as a Legal Standard, 16 Colum. J. Tax L. ___ (2024): Moore v. United States, decided by the Supreme Court in June of this year, reignited discussion about the concept of realization in the income tax. While statutory law
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Zhang Presents Fiscal Citizenship And Taxpayer Privacy Today At Cumberland
Alex Zhang (Emory; Google Scholar) presents Fiscal Citizenship And Taxpayer Privacy, 125 Colum. L. Rev. __ (2025) at Cumberland today as part of its Tax Policy Speake Series hosted by Tracey Roberts: Inequality has reached record levels, and the public shares a common belief that the ultra-rich—while accumulating enormous capital—have not borne their fair share
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Zhang Presents Fiscal Citizenship And Taxpayer Privacy Today At Cumberland
Alex Zhang (Emory; Google Scholar) presents Fiscal Citizenship And Taxpayer Privacy, 125 Colum. L. Rev. __ (2025) at Cumberland today as part of its Tax Policy Speake Series hosted by Tracey Roberts: Inequality has reached record levels, and the public shares a common belief that the ultra-rich—while accumulating enormous capital—have not borne their fair share