Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
-
Avi-Yonah: Bridging The North/South Divide—Tax Competition And Global Justice
Reuven S. Avi-Yonah (Michigan; Google Scholar), Bridging the North/South Divide: Tax Competition and Global Justice: Finding ways to help bridge the North/South divide in terms of life expectancy, health, and living conditions may be the most important task facing humanity in the 21st century. The Sustainable Development Goals adopted by the UN are a beginning
-
Avi-Yonah: Bridging The North/South Divide—Tax Competition And Global Justice
Reuven S. Avi-Yonah (Michigan; Google Scholar), Bridging the North/South Divide: Tax Competition and Global Justice: Finding ways to help bridge the North/South divide in terms of life expectancy, health, and living conditions may be the most important task facing humanity in the 21st century. The Sustainable Development Goals adopted by the UN are a beginning
-
Lesson From The Tax Court: Proving Last Known Address
Many statutes require the IRS to send taxpayers notices. What confuses my students (and many taxpayers) is that the statutes rarely require that the taxpayer actually receive a particular notice; they just require the IRS to properly send the notice. And the IRS will always meet the statutory requirement if the IRS sends the notice
-
Lesson From The Tax Court: Proving Last Known Address
Many statutes require the IRS to send taxpayers notices. What confuses my students (and many taxpayers) is that the statutes rarely require that the taxpayer actually receive a particular notice; they just require the IRS to properly send the notice. And the IRS will always meet the statutory requirement if the IRS sends the notice
-
The Top Five New Tax Papers
There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with new papers debuting on the list at #3, #4, and #5. [889 Downloads] Don't Blame the Victims: Individuals and the MRT, by Karen Alpert (FixTheTaxTreaty.org), John Richardson (TaxResidentAbroad.com) & Laura Snyder (Association of Americans Resident
-
The Top Five New Tax Papers
There is quite a bit of movement in this week's list of the Top 5 Recent Tax Paper Downloads, with new papers debuting on the list at #3, #4, and #5. [889 Downloads] Don't Blame the Victims: Individuals and the MRT, by Karen Alpert (FixTheTaxTreaty.org), John Richardson (TaxResidentAbroad.com) & Laura Snyder (Association of Americans Resident
-
Three New California Tax Articles
David Gamage (Missouri-Columbia; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), Coping With California’s Deficit, Part 1: Borrowing and Taxes, 111 Tax Notes St. 823 (Mar. 18, 2024): In this installment of Academic Perspectives on SALT, Shanske and Gamage examine California’s projected budget deficit and possible solutions. California has a large budget deficit that is
-
Three New California Tax Articles
David Gamage (Missouri-Columbia; Google Scholar) & Darien Shanske (UC-Davis; Google Scholar), Coping With California’s Deficit, Part 1: Borrowing and Taxes, 111 Tax Notes St. 823 (Mar. 18, 2024): In this installment of Academic Perspectives on SALT, Shanske and Gamage examine California’s projected budget deficit and possible solutions. California has a large budget deficit that is
-
Weekly SSRN Tax Article Review And Roundup: Saito Reviews Competing Narratives On OIRA Review Of Tax Regulations By Hickman & Dooling
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Kristin E. Hickman (Minnesota; Google Scholar) & Bridget C.E. Dooling (Ohio State; Google Scholar), Competing Narratives in OIRA Review of Tax Regulations, 19 J.L. Econ. & Pol’y __ (2024): In 2023, the Biden Administration issued a Memorandum of Agreement (MOA) that exempted all tax regulations
-
Weekly SSRN Tax Article Review And Roundup: Saito Reviews Competing Narratives On OIRA Review Of Tax Regulations By Hickman & Dooling
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Kristin E. Hickman (Minnesota; Google Scholar) & Bridget C.E. Dooling (Ohio State; Google Scholar), Competing Narratives in OIRA Review of Tax Regulations, 19 J.L. Econ. & Pol’y __ (2024): In 2023, the Biden Administration issued a Memorandum of Agreement (MOA) that exempted all tax regulations
-
Jensen: The Commerce Clause Doesn’t Override Rules Governing The Taxing Power
Erik M. Jensen (Case Western), The Commerce Clause Doesn't Override Rules Governing the Taxing Power, 182 Tax Notes Fed. 1603 (Feb. 26, 2024): This article challenges the view that the commerce clause, including the foreign commerce part of that clause, provides authority for enacting taxes that don’t meet the explicit requirements for taxes set out
-
Jensen: The Commerce Clause Doesn’t Override Rules Governing The Taxing Power
Erik M. Jensen (Case Western), The Commerce Clause Doesn't Override Rules Governing the Taxing Power, 182 Tax Notes Fed. 1603 (Feb. 26, 2024): This article challenges the view that the commerce clause, including the foreign commerce part of that clause, provides authority for enacting taxes that don’t meet the explicit requirements for taxes set out
-
Optimal Regulatory Enforcement
Giuseppe Dari‐Mattiacci (Amsterdam; Google Scholar) & Alex Raskolnikov (Columbia), Optimal Regulatory Enforcement, 26 Am. L. & Econ. Rev. __ (2024): Criminal law applies to everyone, but regulations constrain only those who choose to participate in a regulated activity. Firms considering such participation face three choices: comply with imperfectly-enforced rules, violate them, or stay out of
-
Optimal Regulatory Enforcement
Giuseppe Dari‐Mattiacci (Amsterdam; Google Scholar) & Alex Raskolnikov (Columbia), Optimal Regulatory Enforcement, 26 Am. L. & Econ. Rev. __ (2024): Criminal law applies to everyone, but regulations constrain only those who choose to participate in a regulated activity. Firms considering such participation face three choices: comply with imperfectly-enforced rules, violate them, or stay out of
-
Are Donor-Advised Funds Facilitating Anonymous Giving To Politically Engaged Charities?
Helen Flannery (Institute for Policy Studies) & Brian Mittendorf (Ohio State; Google Scholar), Are Donor-Advised Funds Facilitating Anonymous Giving to Politically Engaged Charities?: Donor-advised funds are a prominent and rapidly growing charitable giving vehicle. As intermediaries, they serve as a layer of separation between donors and grantees, a layer that provides a significant degree of
-
Are Donor-Advised Funds Facilitating Anonymous Giving To Politically Engaged Charities?
Helen Flannery (Institute for Policy Studies) & Brian Mittendorf (Ohio State; Google Scholar), Are Donor-Advised Funds Facilitating Anonymous Giving to Politically Engaged Charities?: Donor-advised funds are a prominent and rapidly growing charitable giving vehicle. As intermediaries, they serve as a layer of separation between donors and grantees, a layer that provides a significant degree of
-
What A Decision On Affirmative Action Teaches About Taxation
Laura Snyder (Stop Extraterritorial American Taxation; Association of Americans Resident Overseas), What a Decision on Affirmative Action Teaches About Taxation, 51 Rutgers L. Rec. 102 (2023): The U.S. nationality-based tax system discriminates based on nationality (or country of origin). Of all persons living outside the United States, U.S. tax rules classify them based on nationality
-
What A Decision On Affirmative Action Teaches About Taxation
Laura Snyder (Stop Extraterritorial American Taxation; Association of Americans Resident Overseas), What a Decision on Affirmative Action Teaches About Taxation, 51 Rutgers L. Rec. 102 (2023): The U.S. nationality-based tax system discriminates based on nationality (or country of origin). Of all persons living outside the United States, U.S. tax rules classify them based on nationality
-
McMahon: Moore Support For Tax Exceptionalism—Severability In Reconciliation
Stephanie Hunter McMahon (Cincinnati), Moore Support for Tax Exceptionalism: Severability in Reconciliation: Moore v. United States provides the impetus to examine the likely result if the Supreme Court selectively invalidates a revenue-raising provision enacted as part of reconciliation legislation. When Congress uses the reconciliation process, it limits its own power to consider proposals that surpass
-
McMahon: Moore Support For Tax Exceptionalism—Severability In Reconciliation
Stephanie Hunter McMahon (Cincinnati), Moore Support for Tax Exceptionalism: Severability in Reconciliation: Moore v. United States provides the impetus to examine the likely result if the Supreme Court selectively invalidates a revenue-raising provision enacted as part of reconciliation legislation. When Congress uses the reconciliation process, it limits its own power to consider proposals that surpass
-
Disparate Impact In Taxation Meets Disparate Impact Jurisprudence: Burdens vs. Barriers
Steven M. Sheffrin (Tulane; Google Scholar), Disparate Impact in Taxation Meets Disparate Impact Jurisprudence: Burdens vs. Barriers, 43 Va. Tax Rev. 331 (2024): Following years of academic scholarship, the United States Treasury has now embraced disparate racial and ethnic impacts in taxation as an important policy issue. The academic literature highlighted the idea that certain
-
Disparate Impact In Taxation Meets Disparate Impact Jurisprudence: Burdens vs. Barriers
Steven M. Sheffrin (Tulane; Google Scholar), Disparate Impact in Taxation Meets Disparate Impact Jurisprudence: Burdens vs. Barriers, 43 Va. Tax Rev. 331 (2024): Following years of academic scholarship, the United States Treasury has now embraced disparate racial and ethnic impacts in taxation as an important policy issue. The academic literature highlighted the idea that certain
-
When Gender-Affirming Healthcare Becomes Illegal, Will It (Still) Be Tax-Deductible?
Diane Kemker (Southern; Google Scholar), When Gender-Affirming Healthcare Becomes Illegal, Will It (Still) Be Tax-Deductible?, 25 Geo. J. Gender & L. 83 (2023): More than twenty states currently limit or ban access to gender-affirming medical and surgical care for minors, and three more have bans that went into effect on January 1, 2024. For many transgender
-
When Gender-Affirming Healthcare Becomes Illegal, Will It (Still) Be Tax-Deductible?
Diane Kemker (Southern; Google Scholar), When Gender-Affirming Healthcare Becomes Illegal, Will It (Still) Be Tax-Deductible?, 25 Geo. J. Gender & L. 83 (2023): More than twenty states currently limit or ban access to gender-affirming medical and surgical care for minors, and three more have bans that went into effect on January 1, 2024. For many transgender
-
Escajeda: Taxation Of Our Collective And Cumulative Cognitive Inheritance
Hilary G. Escajeda (Mississippi College; Google Scholar), Technology Justice: Taxation of Our Collective and Cumulative Cognitive Inheritance, 56 Loy. L. A. L. Rev. 1073 (2023): As artificial intelligence and robotic technologies accelerate economic transformation, outdated property and tax laws will increasingly fail American workers with ordinary skills that perform routine job functions. Because technology may