Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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Zidar and Zwick: “There’s a Much Better Way to Make Rich People Pay Their Share”
Owen Zidar (Princeton) and Eric Zwick (Chicago Booth) have a new Op-Ed in the New York Times titled “There’s a Much Better Way to Make Rich People Pay Their Share.” From the piece: Policymakers keep adding groups to the list of loophole beneficiaries: incumbent homeowners, venture capital and private equity partners, everywhere millionaires, heirs and,…
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Brunson: Shareholder Democracy, Dual-Class Equity Structures, and Pass-Through Taxation
Samuel Brunson (Loyola-Chicago) has published a new piece on SSRN, “Shareholder Democracy, Dual-Class Equity Structures, and Pass-Through Taxation.” Here’s the abstract: For more than a century, some corporate founders have wanted to maintain control of their corporations, even after the corporation enters the public market. Many have consolidated around one idea: providing a separate class…
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Update on Tariff Challenges
Challenges to President Trump’s various invocation of tariff policies have multiplied, and I figured I would give an update on where each of the challenges currently stands. Section 122 Tariffs These were the tariffs that were imposed in the wake of the President’s loss in Learning Resources, Inc. v. Trump. They expired after 150 days…
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A Beckerian Theory of Taxation
Margaret Chen (Chicago), Mikhail Golosov (Chicago), and Ilia Krasikov (ASU) have a new NBER working paper, “A Beckerian Theory of Taxation.” Here is the abstract: We study taxation in matching environments in which both equilibrium sorting and the sharing of match surplus are endogenous. Tax reforms lead to complex adjustments in sorting and surplus sharing…
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The 2026 SALT Award of Distinction Winner: Richard Pomp
Richard Pomp (The University of Connecticut School of Law) has won Tax Analysts’ 2026 Award of Distinction in U.S. State and Local Taxation. Congratulations! Here is the start of their nice writeup: Perhaps the hardest part of selecting the winner of the 2026 Tax Analysts Award of Distinction in U.S. State and Local Taxation was…
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Musk Would Avoid $2 Billion Tax Bill With Trump Account Donation
Chris Cioffi (Bloomberg Law): Musk Would Avoid $2 Billion Tax Bill With Trump Account Donation Elon Musk’s enormous promise to give a SpaceX share to every child in America could vaporize around $2.6 billion in taxes for Musk….And though receiving stocks in Trump Accounts could be a good deal for holders of the tax-privileged accounts,…
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Kleiman Presents Today at San Diego
Ariel Jurow Kleiman (USC, SSRN), presents at San Diego today as part of its Tax Law Speaker Series. Monday, Nov. 2, 2026 | noon – 1:00 p.m. PSTWarren Hall 2A, University of San Diegostudents welcome / lunch provided / registration not required
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Mazur Presents “Modernizing the IRS in the Age of AI” Today at Pepperdine
Orly Mazur (SMU) presents Modernizing the IRS in the Age of AI, 45 Va. Tax Rev. 182 (2026), at Pepperdine today as part of its Fall 2026 Pepperdine Tax Policy Workshop Series, hosted by Deanna Newton. If you would like to attend any of the workshops (and join the post-workshop lunch), please contact Deanna Newton. Update: Post-workshop lunch:
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Tax Prof Masterminds of California Wealth Tax Bet Their Moment Has Arrived
Bloomberg, Tax-the-Rich Masterminds Bet Their Moment Has Finally Arrived: When Senator Elizabeth Warren ran for president in 2020, she suggested making America’s richest households pay a tax on their wealth. David Gamage was one of the people called in to work on it. Gamage, a University of Missouri tax law professor who worked in the…
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Religious Groups Go Further Than DOJ and Press 5th Circuit for Full Revival of Political Speech by Tax-Exempt Churches
Following up on my previous post, Justice Department Sides With Churches In Political Speech/Tax-Exempt Status Case: Bloomberg Law, Religious Groups Press for Full Revival of Political Speech Suit: Religious groups are urging a federal appeals court to fully reverse a lower court’s dismissal of their challenge to a ban on churches engaging in political activity,…
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IRS Hiring Spree Signals Enforcement Shift, Targets Wealthy
Bloomberg Law, As IRS Hires Again, Private Sector Watches for Enforcement Shift: A renewed hiring effort from the IRS in its compliance divisions is signaling to the private sector that it isn’t shying away from enforcement. IRS Chief of Compliance Jarod Koopman said last week the IRS is hiring roughly 1,000 workers for the small…
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The IRS Has a $180 Million Ghost-Preparer Problem
Ghost preparers have long haunted the United States’ tax system. In the mid-1970s, employees at the ten IRS service centers sorted incoming returns into “fats and flats“—thick envelopes stuffed with multiple returns, compared to slim(mer) single-return mailings. Employees then examined the contents of the “odd” deliveries “to see whether the returns were signed by a…
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Does AI Increase Systemic Risk for BigLaw “Bank Runs”?
On October 28, senior partners at storied Wall Street firm Weil, Gotshal & Manges announced their recommendation to dissolve the 95-year-old law firm. Some found irony in the announcement, given the firm’s longstanding leadership in bankruptcy practice (including in tax). Some vented about the timing and substance of the communication—and asked what was next for…
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Halloween at America’s Law Schools, 2026
From haunted law reviews and faculty costume contests to trick-or-treating, fresh apple cider, and atrocious puns, law schools across the United States celebrated Halloween in 2026. (These are past events; sponsors and organizers are omitted.) The takeaway: the library is a hot spot for trick-or-treating! Especially given candy prices these days. A roundup of events…
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Cooper et al.: A Sin Ban, Not a Sin Tax?
Crossan Cooper, Katja Seim & Jintaek Song, A Sin Ban, Not a Sin Tax? Consumption and Incidence of SNAP Soda Restrictions, NBER Working Paper No. 35739 (Sep. 2026): We study the first statewide SNAP restrictions on sweetened beverages and candy. Restricted spending falls 11 percent; calories and sugar fall 5–8 percent. Substitution is asymmetric: eligible…
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Pigou Returns! Halloween Edition
It’s Halloween, and the media (and Reddit) are talking candy! Prices are up, and sales are down—for large and extra-large bags. Small bags? Sales are up, in total dollar terms. In the age of affordability, consumers may be more discerning, according to Sally Lyons Wyatt, a global executive vice president and food industry adviser for…
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SSRN Review & Roundup: Narotzki Reviews Hanna’s A New View of Taxation
This week, Doron Narotzki (Akron; Google Scholar) reviews a new work by Christopher H. Hanna (SMU; SSRN), A New View of Taxation, 28 U. Pa. J. Bus. L. 317 (2026). Christopher Hanna’s article explains how distinguishing normal investment returns from supernormal returns changes our understanding of familiar tax rules. Hanna connects tax theory, empirical research,…
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Kern: Optimal Avoidability in Cross-Border Minimum Taxation
Adam Kern (University of San Diego) recently published Optimal Avoidability in Cross-Border Minimum Taxation in the Journal of Public Economics: Many tax regimes collect revenue to the extent that other governments do not. This paper develops a theory of how such cross-border minimum taxes should be designed, focusing on choices that affect avoidance of the…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 77 (October 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron:
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Jotwell: Tax : The Billionaire Tax: Dispassionate Analysis of a Policy that We Desperately Need
Neil H. Buchanan (Florida), Tax : The Billionaire Tax: Dispassionate Analysis of a Policy that We Desperately Need (reviewing Brian Galle, David Gamage, Emmanuel Saez, and Darien Shanske, Expert Report on the California 2026 Billionaire Tax: Revenue, Economic, and Constitutional Analysis): California and New York City are the current epicenters of efforts to slightly increase…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 76 (October 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron:
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Hanna: A New View of Taxation
Christopher Hanna (SMU) has recently published a new article, forthcoming in the University of Pennsylvania Journal of Business Law, titled “A New View of Taxation.” Here’s the abstract: Tax scholars have made a number of breakthrough discoveries in tax law going back to at least Thomas Hobbes and his observations on a consumption tax almost…
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N.Y. Times: Inside the Billionaires’ War Against California’s Proposed Wealth Tax
In the New York Times, Theodore Schleifer and Erin Griffith have a report, “Inside the Billionaires’ War Against California’s Proposed Wealth Tax.” From the article: Every Tuesday for the last few months, two dozen of the world’s richest people or their advisers hop onto a conference call and plan for war. The war is against…
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AccessLex Submits Comment Urging IRS to Withdraw Proposed Rule
Earlier this week, AccessLex Institute submitted a formal letter urging the IRS to withdraw its proposed rule impacting private school tax exemption (proposed regulations – REG-119986-25). From the letter: The following comments reflect AccessLex Institute’s view that the proposed rule expands existing law beyond what Supreme Court precedent requires, and fails to adequately account for…
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Hemel Presents “Death, Taxes, and Chicks” Today at Missouri
Daniel Hemel (NYU) will present Death, Taxes, and Chicks at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be only be open to guest participants live. Anyone who would like to join as a guest participant should email Professor Gamage directly for…