Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
-
Kysar: The Global Tax Deal And The New International Economic Governance
Rebecca M. Kysar (Fordham; Google Scholar), The Global Tax Deal and the New International Economic Governance, 77 Tax L. Rev. __ (2024): The ethos of economic integration and trade liberation no longer reigns supreme. Instead of multilateral trade agreements, nations are turning towards protectionism and unilateralism. Yet in late 2021, nearly 140 countries agreed to
-
Kysar: The Global Tax Deal And The New International Economic Governance
Rebecca M. Kysar (Fordham; Google Scholar), The Global Tax Deal and the New International Economic Governance, 77 Tax L. Rev. __ (2024): The ethos of economic integration and trade liberation no longer reigns supreme. Instead of multilateral trade agreements, nations are turning towards protectionism and unilateralism. Yet in late 2021, nearly 140 countries agreed to
-
The Kinder, Gentler IRS? Where?
Harvey Gilmore (Hartford), The Kinder, Gentler IRS? Where?, 21 DePaul Bus. & Com. L.J. 31 (2022): I was a practicing accountant for the better part of ten years. I prepared income tax returns, sales tax returns, property tax returns, payroll tax returns, and New York City Commercial Rent tax returns. Over the years, I’ve also
-
The Kinder, Gentler IRS? Where?
Harvey Gilmore (Hartford), The Kinder, Gentler IRS? Where?, 21 DePaul Bus. & Com. L.J. 31 (2022): I was a practicing accountant for the better part of ten years. I prepared income tax returns, sales tax returns, property tax returns, payroll tax returns, and New York City Commercial Rent tax returns. Over the years, I’ve also
-
A Future for Carbon Taxation?
Myanna Dellinger (EinStrong Foundation), A Future for Carbon Taxation?, 46 Fordham Int'l L.J. 659 (2023): Carbon taxation has been the topic of academic and political discussions for quite some time. With the exception of some Northern European countries, far too few states or nations have adopted taxation in amounts likely to impact climate change mitigation
-
A Future for Carbon Taxation?
Myanna Dellinger (EinStrong Foundation), A Future for Carbon Taxation?, 46 Fordham Int'l L.J. 659 (2023): Carbon taxation has been the topic of academic and political discussions for quite some time. With the exception of some Northern European countries, far too few states or nations have adopted taxation in amounts likely to impact climate change mitigation
-
Hasen: Taxation Of Work In Christian Theology
David Hasen (Florida; Google Scholar), Taxation of Work in Christian Theology: How should Christian theological principles inform rules for the taxation of work? The answer to this question is ambiguous because work plays an ambiguous role in the life of the believer. Scripture accords dignity to work, but work, like almost any activity, can become
-
Hasen: Taxation Of Work In Christian Theology
David Hasen (Florida; Google Scholar), Taxation of Work in Christian Theology: How should Christian theological principles inform rules for the taxation of work? The answer to this question is ambiguous because work plays an ambiguous role in the life of the believer. Scripture accords dignity to work, but work, like almost any activity, can become
-
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. [879 Downloads] Don't Blame the Victims: Individuals and the MRT, by Karen Alpert (FixTheTax Treaty.org), John Richardson (TaxResidentAbroad.com) & Laura Snyder (Association of Americans Resident Overseas) [569 Downloads] No More Tax-Free Lunch for Billionaires: Closing the Borrowing
-
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. [879 Downloads] Don't Blame the Victims: Individuals and the MRT, by Karen Alpert (FixTheTax Treaty.org), John Richardson (TaxResidentAbroad.com) & Laura Snyder (Association of Americans Resident Overseas) [569 Downloads] No More Tax-Free Lunch for Billionaires: Closing the Borrowing
-
Hatfield: Safeguarding Taxpayer Data
Michael Hatfield (University of Washington; Google Scholar), Safeguarding Taxpayer Data, 26 Fla. Tax Rev. ___ (2023): The Internal Revenue Service (IRS) collects more information on more individuals than any other government agency. The information is not only financial but personal, potentially including information about health care needs and decisions; the caregivers, disabilities, and foreign birth
-
Hatfield: Safeguarding Taxpayer Data
Michael Hatfield (University of Washington; Google Scholar), Safeguarding Taxpayer Data, 26 Fla. Tax Rev. ___ (2023): The Internal Revenue Service (IRS) collects more information on more individuals than any other government agency. The information is not only financial but personal, potentially including information about health care needs and decisions; the caregivers, disabilities, and foreign birth
-
Weekly SSRN Tax Article Review And Roundup: Roberts Reviews The Missing “T” in ESG By Chaim & Parchomovsky
This week, Tracey M. Roberts (Cumberland; Google Scholar) reviews a new work by Danielle A. Chaim (Bar-Ilan; Google Scholar) and Gideon Parchomovsky (Penn; Google Scholar), The Missing “T” in ESG, 77 Vanderbilt L. Rev. 789 (2024). In The Missing T in ESG, Danielle Chaim and Gideon Parchomovsky take a magnifying glass to ESG investing and
-
Weekly SSRN Tax Article Review And Roundup: Roberts Reviews The Missing “T” in ESG By Chaim & Parchomovsky
This week, Tracey M. Roberts (Cumberland; Google Scholar) reviews a new work by Danielle A. Chaim (Bar-Ilan; Google Scholar) and Gideon Parchomovsky (Penn; Google Scholar), The Missing “T” in ESG, 77 Vanderbilt L. Rev. 789 (2024). In The Missing T in ESG, Danielle Chaim and Gideon Parchomovsky take a magnifying glass to ESG investing and
-
Next Week’s Tax Workshop
Friday, May 24: Guido Alfani (Bocconi University; Google Scholar) will present Economic Inequality in Preindustrial Times: Europe and Beyond, 59 J. Econ. Lit. 3 (2021), as part of the Oxford-Virginia Legal Dialogs. If you would like to attend, please RSVP.
-
Next Week’s Tax Workshop
Friday, May 24: Guido Alfani (Bocconi University; Google Scholar) will present Economic Inequality in Preindustrial Times: Europe and Beyond, 59 J. Econ. Lit. 3 (2021), as part of the Oxford-Virginia Legal Dialogs. If you would like to attend, please RSVP.
-
Parsons: Cryptocurrency, Legibility, And Taxation
Amanda Parsons (Colorado; Google Scholar), Cryptocurrency, Legibility, and Taxation, 72 Duke L.J. Online 1 (2022): In Jarrett v. United States, a taxpayer in Tennessee is arguing that staking cryptocurrency did not result in him earning “income” under federal income tax law. This case illustrates the fundamental challenge that cryptocurrency and blockchain technology present for tax
-
Parsons: Cryptocurrency, Legibility, And Taxation
Amanda Parsons (Colorado; Google Scholar), Cryptocurrency, Legibility, and Taxation, 72 Duke L.J. Online 1 (2022): In Jarrett v. United States, a taxpayer in Tennessee is arguing that staking cryptocurrency did not result in him earning “income” under federal income tax law. This case illustrates the fundamental challenge that cryptocurrency and blockchain technology present for tax
-
Hayashi & Deeks: Tax Sanctions And The Russia-Ukraine Conflict
Andrew T. Hayashi (Virginia; Google Scholar) & Ashley Deeks (Virginia; Google Scholar), Tax Sanctions and the Russia-Ukraine Conflict, 48 N.C. J. Int'l L. 433 (2023): The Russian invasion of Ukraine in 2022 provoked the imposition of economic sanctions that are unprecedented in their swiftness, severity, and novelty. In this essay, we evaluate the possible role
-
Hayashi & Deeks: Tax Sanctions And The Russia-Ukraine Conflict
Andrew T. Hayashi (Virginia; Google Scholar) & Ashley Deeks (Virginia; Google Scholar), Tax Sanctions and the Russia-Ukraine Conflict, 48 N.C. J. Int'l L. 433 (2023): The Russian invasion of Ukraine in 2022 provoked the imposition of economic sanctions that are unprecedented in their swiftness, severity, and novelty. In this essay, we evaluate the possible role
-
Estate Tax Consequences Of Redeeming Stock With Life Insurance Proceeds
Timothy M. Todd (Liberty; Google Scholar) & Philip Manns (Liberty), Seeing Through the Sleight of Hand: Estate Tax Consequences of Redeeming Stock With Life Insurance Proceeds, 183 Tax Notes Fed. 437 (Apr. 15, 2024): The Supreme Court granted certiorari in Connelly v. United States to resolve a circuit court split concerning the federal estate tax
-
Estate Tax Consequences Of Redeeming Stock With Life Insurance Proceeds
Timothy M. Todd (Liberty; Google Scholar) & Philip Manns (Liberty), Seeing Through the Sleight of Hand: Estate Tax Consequences of Redeeming Stock With Life Insurance Proceeds, 183 Tax Notes Fed. 437 (Apr. 15, 2024): The Supreme Court granted certiorari in Connelly v. United States to resolve a circuit court split concerning the federal estate tax
-
Grewal: The Mandatory Repatriation Tax Is Not A Tax
Andy Grewal (Iowa; Google Scholar), The Mandatory Repatriation Tax Is Not a Tax: In Moore v. United States, the Supreme Court has agreed to address whether the Sixteenth Amendment allows Congress to tax unrealized sums. The case arises over Section 965(a). Under that section, taxpayers with substantial equity interests in a foreign corporation must immediately
-
Grewal: The Mandatory Repatriation Tax Is Not A Tax
Andy Grewal (Iowa; Google Scholar), The Mandatory Repatriation Tax Is Not a Tax: In Moore v. United States, the Supreme Court has agreed to address whether the Sixteenth Amendment allows Congress to tax unrealized sums. The case arises over Section 965(a). Under that section, taxpayers with substantial equity interests in a foreign corporation must immediately
-
Step-Up In Basis: Policy Perspectives On A Longstanding Policy Loophole
Bridget J. Crawford (Pace; Google Scholar), Crystal Lichtenberger (Pace), Kaitlyn Maguire (Pace) & Gigi McQuillan (Pace), Step-Up in Basis: Policy Perspectives on a Longstanding Policy Loophole, 7 Bus. & Fin. L. Rev. __ (2024): This essay offers three different and conflicting perspectives on the income tax step-up in basis for property acquired from a decedent