Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Scholarship
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The Rise Of Pass-Throughs: An Empirical Investigation
Sebastian Dyrda (Toronto; Google Scholar) & Benjamin W. Pugsley (Notre Dame; Google Scholar), The Rise of Pass-Throughs: An Empirical Investigation: Pass-through entities have emerged as the leading U.S. business organization form in recent decades. Using comprehensive confidential administrative data, this paper highlights five core findings: (1) the rise in pass-throughs is pervasive across industries and
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The Rise Of Pass-Throughs: An Empirical Investigation
Sebastian Dyrda (Toronto; Google Scholar) & Benjamin W. Pugsley (Notre Dame; Google Scholar), The Rise of Pass-Throughs: An Empirical Investigation: Pass-through entities have emerged as the leading U.S. business organization form in recent decades. Using comprehensive confidential administrative data, this paper highlights five core findings: (1) the rise in pass-throughs is pervasive across industries and
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Columbia Tax Workshop (Day 2)
Today's Columbia Tax Workshop is being held at its Manhattanville Campus: Katarzyna Bilicka (Utah State; Google Scholar), The Role of Intellectual Property in Tax Planning (with Paul Organ (U.S. Treasury Department; Google Scholar) & İrem Güçeri (Oxford; Google Scholar)) Discussant: Michael Love (Columbia) Multinational enterprises (MNEs) that invest in research and development (R&D) and innovation find it easier to
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Columbia Tax Workshop (Day 2)
Today's Columbia Tax Workshop is being held at its Manhattanville Campus: Katarzyna Bilicka (Utah State; Google Scholar), The Role of Intellectual Property in Tax Planning (with Paul Organ (U.S. Treasury Department; Google Scholar) & İrem Güçeri (Oxford; Google Scholar)) Discussant: Michael Love (Columbia) Multinational enterprises (MNEs) that invest in research and development (R&D) and innovation find it easier to
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Columbia Tax Workshop (Day 1)
Today's Columbia Tax Workshop is being held at its Manhattanville Campus: Kimberly Clausing (UCLA; Google Scholar), Capital Taxation and Market PowerDiscussant: Wojciech Kopczuk (Columbia; Google Scholar) In recent decades, market power has increased substantially, according to multiple measures that describe industry concentration, mark-ups, and business profitability. While market power can generate benefits, it also raises vexing
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Columbia Tax Workshop (Day 1)
Today's Columbia Tax Workshop is being held at its Manhattanville Campus: Kimberly Clausing (UCLA; Google Scholar), Capital Taxation and Market PowerDiscussant: Wojciech Kopczuk (Columbia; Google Scholar) In recent decades, market power has increased substantially, according to multiple measures that describe industry concentration, mark-ups, and business profitability. While market power can generate benefits, it also raises vexing
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Lesson From The Tax Court: When Is An Excise Tax Really A Penalty?
“The power to tax involves the power to destroy.” Justice John Marshall in McCulloch v. Maryland, 17 U.S. 316, 431 (1819). “Sometimes a tax is…just a tax.” — Sigmund Freud’s Tax Advisor. Today’s lesson is about how to tell when an excise tax is really a penalty. The answer I learn is: “why do you
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Lesson From The Tax Court: When Is An Excise Tax Really A Penalty?
“The power to tax involves the power to destroy.” Justice John Marshall in McCulloch v. Maryland, 17 U.S. 316, 431 (1819). “Sometimes a tax is…just a tax.” — Sigmund Freud’s Tax Advisor. Today’s lesson is about how to tell when an excise tax is really a penalty. The answer I learn is: “why do you
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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. [873 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) [541 Downloads] No More Tax-Free Lunch for Billionaires: Closing the Borrowing
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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. [873 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) [541 Downloads] No More Tax-Free Lunch for Billionaires: Closing the Borrowing
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Efficiency vs. Welfare In Benefit-Cost Analysis — The Case Of Government Funding By Liscow & Sunstein
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews Zachary D. Liscow (Yale; Google Scholar) & Cass R. Sunstein (Harvard; Google Scholar), Efficiency vs. Welfare in Benefit-Cost Analysis: The Case of Government Funding, 15 J. Benefit-Cost Analysis ___ (2024). Benefit-Cost Analysis (“BCA”) is a methodical approach to assessing the economic advantages and disadvantages of different options that
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Efficiency vs. Welfare In Benefit-Cost Analysis — The Case Of Government Funding By Liscow & Sunstein
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews Zachary D. Liscow (Yale; Google Scholar) & Cass R. Sunstein (Harvard; Google Scholar), Efficiency vs. Welfare in Benefit-Cost Analysis: The Case of Government Funding, 15 J. Benefit-Cost Analysis ___ (2024). Benefit-Cost Analysis (“BCA”) is a methodical approach to assessing the economic advantages and disadvantages of different options that
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Zhang: Fiscal Citizenship And Taxpayer Privacy
Alex Zhang (Emory; Google Scholar), Fiscal Citizenship and Taxpayer Privacy, 125 Colum. L. Rev. __ (2025): 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 of tax burdens. In response, commentators have called for transparency in the tax records of the
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Zhang: Fiscal Citizenship And Taxpayer Privacy
Alex Zhang (Emory; Google Scholar), Fiscal Citizenship and Taxpayer Privacy, 125 Colum. L. Rev. __ (2025): 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 of tax burdens. In response, commentators have called for transparency in the tax records of the
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Lipman: Not Taxing Puerto Rico—Whitewashing Impoverishment In United States v. Vaello Madero
Francine J. Lipman (UNLV; Google Scholar), Not Taxing Puerto Rico: Whitewashing Impoverishment in United States v. Vaello Madero, 77 Tax Law. 357 (2024): Puerto Rico is a lush archipelago located between the Caribbean Sea and the North Atlantic Ocean. More than three million U.S. citizens with diverse racial and ethnic histories and cultures live on
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Lipman: Not Taxing Puerto Rico—Whitewashing Impoverishment In United States v. Vaello Madero
Francine J. Lipman (UNLV; Google Scholar), Not Taxing Puerto Rico: Whitewashing Impoverishment in United States v. Vaello Madero, 77 Tax Law. 357 (2024): Puerto Rico is a lush archipelago located between the Caribbean Sea and the North Atlantic Ocean. More than three million U.S. citizens with diverse racial and ethnic histories and cultures live on
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Mayer: Charity Law And Blockchain Technology
Lloyd Hitoshi Mayer (Notre Dame; Google Scholar), Charity Law & Blockchain Technology: Using Old Wineskins for New Wine?, 77 Tax Law. __ (2024): Whenever something new emerges, the question of how existing law applies arises. Sometimes it is both easy to answer that question and the answer is consistent with the policy goals of existing
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Mayer: Charity Law And Blockchain Technology
Lloyd Hitoshi Mayer (Notre Dame; Google Scholar), Charity Law & Blockchain Technology: Using Old Wineskins for New Wine?, 77 Tax Law. __ (2024): Whenever something new emerges, the question of how existing law applies arises. Sometimes it is both easy to answer that question and the answer is consistent with the policy goals of existing
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Pepperdine Tax Policy Workshop Series (Spring 2024)
Thanks to Deanna Newton, the faculty who came to Malibu, and our students who made the Spring 2024 Pepperdine Tax Policy Workshop Series such a rousing success: January 22: Jason Oh (UCLA), How Does The Corporate Tax Distort Choice Of Corporate Governance? February 5: Ariel Jurow Kleiman (Loyola-L.A.; Google Scholar), Taxing Nannies (with Shayak Sarkar
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Pepperdine Tax Policy Workshop Series (Spring 2024)
Thanks to Deanna Newton, the faculty who came to Malibu, and our students who made the Spring 2024 Pepperdine Tax Policy Workshop Series such a rousing success: January 22: Jason Oh (UCLA), How Does The Corporate Tax Distort Choice Of Corporate Governance? February 5: Ariel Jurow Kleiman (Loyola-L.A.; Google Scholar), Taxing Nannies (with Shayak Sarkar
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Morse: The Truth About Safe Harbors
Susan C. Morse (Texas; Google Scholar), The Truth About Safe Harbors, 92 Tenn. L. Rev. __ (2025): Safe harbors are everywhere in law. Safe harbors have a modest, gentle appearance. They provide by rule that particular facts comply with the law and will result in no penalty. They are otherwise silent. This modest appearance conceals
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Morse: The Truth About Safe Harbors
Susan C. Morse (Texas; Google Scholar), The Truth About Safe Harbors, 92 Tenn. L. Rev. __ (2025): Safe harbors are everywhere in law. Safe harbors have a modest, gentle appearance. They provide by rule that particular facts comply with the law and will result in no penalty. They are otherwise silent. This modest appearance conceals
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Thimmesch Reviews Layser’s State Tax Incentive Reform
Adam Thimmesch (Nebraska; Google Scholar), Opportunity and Obstacle: State Tax Incentives and the Fight Against Poverty (JOTWELL) (reviewing Michelle D. Layser (San Diego; Google Scholar), Removing Barriers to State Tax Incentive Reform, 171 U. Pa. L. Rev. 5 (2023)): The stark contrast between the United States’ widespread prosperity and the deep-seated poverty afflicting many of its
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Thimmesch Reviews Layser’s State Tax Incentive Reform
Adam Thimmesch (Nebraska; Google Scholar), Opportunity and Obstacle: State Tax Incentives and the Fight Against Poverty (JOTWELL) (reviewing Michelle D. Layser (San Diego; Google Scholar), Removing Barriers to State Tax Incentive Reform, 171 U. Pa. L. Rev. 5 (2023)): The stark contrast between the United States’ widespread prosperity and the deep-seated poverty afflicting many of its
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17 Ways To Regulate BigTech With Tax
Allison Christians (McGill; Google Scholar) & Tarcísio Diniz Magalhães (Antwerp; Google Scholar), 17 Ways to Regulate BigTech with Tax, 77 Tax Law. __ (2024): BigTech’s outsize power and influence have prompted policymakers and experts in the United States and around the world to turn to taxation both for the sake of raising revenue and as