Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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San Francisco Voters Reject Expanded “Overpaid CEO” Tax
Eliyahu Kamisher & Biz Carson (Bloomberg Law): Billionaires Win as Voters Halt San Francisco ‘Overpaid CEO’ Tax San Francisco voters rejected a union-backed ballot measure to raise taxes on large corporations doing business in the city, a win for billionaires who argued that the levy would harm the city’s economic recovery. The Overpaid CEO Act, known as…
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WSJ: Stock Gains Without All the Taxes?
Miriam Gottfried & Peter Santilli (Wall Street Journal): Stock Gains Without All the Taxes? How the Hottest Trade on Wall Street Works With the stock market near record highs, it isn’t enough to be winning anymore. Wealthy investors are now obsessed with losing, too. The hottest investment on Wall Street promises a magical-sounding mix of…
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NY Times: How to Tax AI
New York Times DealBook: Everyone Wants to Tax A.I. The Big Disagreement: How?, by Peter Coy: Artificial intelligence is making some people rich and others feel left out. Unsurprisingly, then, proposals to tax A.I. for the benefit of the public are multiplying like the fingers on an A.I.-generated hand. Some make sense. Others, not so…
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Columbia Journal Of Tax Law Publishes New Issue
The Columbia Journal of Tax Law has published a new issue (Vol. 17, No. 1 (Fall 2025)): Jeremy Bearer-Friend (George Washington) & Sarah Polcz (UC-Davis), Sharing the Algorithm: The Tax Solution to Generative AI, 17 Colum. J. Tax L. 1 (2025) (reviewed by Assaf Harpaz (Georgia) here): Tax policy offers a core tool for mitigating…
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Jock Taxes and the NBA Finals
The NBA Finals continue Saturday evening, when the New York Knicks have an opportunity to conclude their series against the San Antonio Spurs. If the Spurs extend the series, then they’ll face additional New York “duty days” for Game 6. By contrast, Texas has no income tax and no jock-tax regime. This asymmetry affects players—and…
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Lunar et al.: GradeLegal: Automated Grading for German Legal Cases
Abdullah Al Zubaer (U. Passau), Lorenz Wendlinger (Deggendorf Inst. Tech.), Simon Alexander Nonn (U. Passau), Michael Granitzer (U. Passau) & Jelena Mitrović (U. Passau), GradeLegal: Automated Grading for German Legal Cases, arXiv:2605.21076 (cs) (May 20, 2026):
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Pasin et al.: An Experimental Study on Institutions and Social Norms of Tax Compliance
Gian Luca Pasin (Inst. of Cognitive Sci., CNR), Aron Szekely (Inst. of Cognitive Sci., CNR) & Flaminio Squazzoni (U. Milan, Dept. Soc. & Pol. Sci.), An Experimental Study on Institutions and Social Norms of Tax Compliance, 42 Eur. Soc. Rev. 442 (2026):
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Somin: H-1B Visa Fee Ruling Extends Learning Resources Beyond Tariffs
Jon Endean previously covered Judge Leo T. Sorokin’s decision (D. Mass.) holding that the Trump Administration’s $100,000 H-1B visa fee is a tax that exceeds the authority Congress delegated to the Executive Branch. The Supreme Court’s decision invalidating the Trump Administration’s IEEPA tariffs in Learning Resources figured prominently in Sorokin’s decision. The government is expected…
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SSRN Review & Roundup: Endean Reviews Cui’s Retaliatory Taxation and the Birth of America’s First Tax Treaty
This week, Jon Endean (Brooklyn) reviews a new work by Wei Cui (British Columbia), Retaliatory Taxation and the Birth of America’s First Tax Treaty (June 10, 2026). Income tax treaties are a cornerstone of cross-border taxation in the United States, allowing individuals and companies eligible for treaty benefits to get relief from double taxation. The…
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Bloomberg: IRS, Canada Agree on World Cup Participants’ Income Allocation
Michael Rapoport (Bloomberg): IRS, Canada Agree on World Cup Participants’ Income Allocation: Participants of the 2026 FIFA World Cup can use a proportional formula to allocate the prize money and other compensation they receive among the countries hosting the tournament, the IRS said Wednesday. The IRS and the Canada Revenue Agency have agreed on a…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 47 (June 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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Thorndike: “Subjugation With a Budget Line: How Tax Law Protected Slavery”
Joseph J. Thorndike, Subjugation With a Budget Line: How Tax Law Protected Slavery (reviewing Anthony C. Infanti (Pittsburgh) The Human Toll: Taxation and Slavery in Colonial America)): In South Carolina’s Colonial era, executing an enslaved person created a problem. The colony’s slave code — the body of law that defined slavery, established slaveholders’ authority, and…
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Hemel: Taxation and Animals
Daniel Hemel gave the Norman A. Sugarman Tax Lecture, titled “Taxation and Animals,” at Case Western Reserve University School of Law on March 17, 2026. The accompanying piece will appear in volume 77 of the Case Western Law Review. Here is the abstract to that piece: Animals have played a central role in tax systems…
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Dale, Hemel & Manny: DAF Sponsors Should Stand Up for Nonprofit Sector Independence
Harvey Dale (NYU), Daniel Hemel (NYU), and Jill Manny (NYU), have a new piece in Tax Notes, DAF Sponsors Should Stand Up for Nonprofit Sector Independence, 191 Tax Notes Fed. 1305 (May 25, 2026). Here’s the abstract: The three largest sponsors of donor-advised funds jolted the philanthropic world in recent weeks when they announced that…
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$100,000 H-1B Visa Fee Ruled Unlawful
In a challenge brought by twenty states challenging President Trump’s $100,000 fee imposed on employers seeking new H-1B visas, Judge Leo T. Sorokin (D. Mass.) ruled in favor of the plaintiffs, vacating the associated policy. From the opinion: The Court begins with Plaintiffs’ assertion that the Policy intrudes upon Congress’s taxing power. The first inquiry…
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National Tax Journal Publishes New Issue
The National Tax Journal has published volume 79, number 2 (March 2026): Zero Deng (Oregon State, Business) & Scott G. Rane (Florida, Business), The Foreign Market Effect and Estimating Tax-Motivated Income Shifting, 79 Nat’l Tax J. 267 (2026). Grace Brang (NYU Wagner), Sewin Chan (NYU Wagner) & Travis St. Clair (NYU Wagner), Fiscal Stimulus or Debt Relief:…
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Bearer-Friend and Polcz on Taxing Ai and the American Ai Sovereign Wealth Fund Act
Jeremy Bearer-Friend (GW) and Sarah Polcz’s (UC Davis) proposal for taxing generative Ai has received some recent and notable attention. In a recent New York Times op-ed, Bernie Sanders referenced it as a basis for his now-introduced American AI Sovereign Wealth Fund Act. The Ari Melber show on MSN did a segment on the proposal…
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Goshen, Hamdani, and Raskolnikov: The Regressive Effects of Climate Stewardship
Zohar Goshen (Columbia), Assaf Hamdani (Oxford), and Alex Raskolnikov (Columbia) have published “Poor ESG: Regressive Effects of Climate Stewardship” in the Brigham Young University Law Review. Here is the abstract: The rise of inequality and global warming are the two ultimate challenges of our time. After decades of congressional failure to address climate change, the…
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Avi-Yonah: Taxation and Birthright Citizenship
Reuven Avi-Yonah (Michigan), “Taxation and Birthright Citizenship” (Tax Notes, June 8, 2026): Under the 14th Amendment, individuals who are born in the United States are U.S. citizens and citizens of the state where they reside if they are “subject to the jurisdiction” of the United States. The debate surrounding birthright citizenship focuses on the meaning…
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JOTWELL: Jury Rights in Civil Tax Cases??
Susan Morse (Texas): Jury Rights in Civil Tax Cases?? (reviewing Steve R. Johnson (FSU), Jarkesy, the Seventh Amendment, and Tax Penalties, 79 U. Mia. L. Rev. 461 (2025)) Does the Seventh Amendment provide a taxpayer with the right to a jury before the government imposes tax penalties? This issue is live at the Tax Court, at Courts of Appeals,…
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SALT Updates From the First Half of 2026
Billy Hamilton (Tax Notes): To Be Continued: Legislative Sessions End; Some Issues Don’t David Brunori (Law360): A Playground Of Unsound Tax Policy: SALT In Review Maria Koklanaris (Law360): State & Local Tax Takeaways From May
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New York Appellate Court Oral Arguments in Zelinsky Remote Work Case
The New York Supreme Court, Appellate Division, Third Department, held oral arguments in tax law professor Edward Zelinsky’s challenge of New York’s “convenience of the employer” rule. Specifically, Prof. Zelinsky is asserting that New York improperly sourced his employment income to New York during the COVID-19 pandemic when the government forced Cardozo to close and…
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Layser: Renters’ Tax Credits
Michelle Layser (San Diego), Renters’ Tax Credits, 113 Geo. L.J. 1107 (2025): America is facing an affordable housing crisis that current policies have failed to mitigate. Even before the COVID-19 pandemic, half of American tenants were rent burdened, paying more than one-third of their income on rent. For this reason, Renters’ Tax Credit (RTC) proposals are gaining…
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Trump Lets IRS Fire More Positions at Will
Bloomberg Law, IRS Can Fire More Positions at Will With Trump Executive Order: Trump’s order strips job security from almost 8,000 federal positions. Under Office of Personnel Management regulations, employees moved into a new job classification—known as Schedule Policy/Career—lose many of the procedural protections most federal workers have, including the right to appeal their removal to an independent…
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NYU Hosts AMT/EITC Conference
On June 4 and 5, 2026, NYU School of Law hosted the 2026 Association of Mid-Career Tax Scholars/Experienced in Tax Joint Conference (AMT/EITC). Participants and panels, below the fold.