Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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Jaitley et al.: Artificial Intelligence in Federal Courts
Anika Jaitley (Northwestern), Daniel W. Linna Jr. (Northwestern), Xavier Rodriguez (W.D. Texas),V.S. Subrahmanian (Northwestern) & Siyu Tao (Northwestern), Artificial Intelligence in Federal Courts: ARandom-Sample Survey of Judges, 27 Sedona Conf. J. _ (forthcoming 2026):
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Faccio & Manfredonia: Taxes and Financial Distress
Mara Faccio (Purdue) & Stephano Manfredonia (Fordham), Taxes and Financial Distress: Evidence from Establishment-Level Data, NBER Working Paper No. 35134 (Apr. 2026):
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ITEP: Taxing Advertising for the Information Age
This proposal—to impose sales tax on digital advertising—straddles the categories of subnational data taxes and gross-revenue digital services taxes. At present, Maryland, Utah, and Washington have sales taxes that expressly reach the sale of these advertising services. A report from the Institute for Taxation and Economic Policy, below the fold.
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SSRN Review & Roundup: Marks Reviews Lawsky’s Limiting Inconsistencies in Legal Languages
This week, Noah H. Marks (UNC) reviews a new article by Sarah B. Lawsky (Illinois), Limiting Inconsistencies in Legal Languages, 28 Vanderbilt J. Ent. & Tech. L. 765 (2026). Tax practitioners, professors, and students are all too aware that the Code, despite its interconnectedness and intricacies, is far from a logically consistent, unified whole. Overlapping…
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New York Times: Trump Clears Way for Corporate Tax Dodge Hidden in the Fine Print
Jesse Drucker & Dyland Freedman, Trump Clears Way for Corporate Tax Dodge Hidden in the Fine Print (New York Times, May 29, 2026) A year ago, the Trump administration withdrew from a global effort to curb offshore tax-dodging by multinational companies. That decision has been a huge gift to corporate America, enabling companies to avoid…
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WSJ: The GOP Wants to Tax Your Car
Kimberley A. Strassel, The GOP Wants to Tax Your Car (Wall Street Journal, May 28, 2026) Campaign slogans can be catchy, clumsy or clever. Few are as crazy as the one Republicans are setting themselves up for this fall: “Vote GOP. The party that brought you a national car tax.” The House Transportation and Infrastructure…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 43 (May 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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Bloomberg: “Biofuel Groups Push IRS for New Model to Calculate Tax Credit”
Erin Schilling (Bloomberg): Biofuel Groups Push IRS for New Model to Calculate Tax Credit: Biofuel and farm groups are asking the Treasury Department and IRS to update the model companies use to calculate whether they qualify for the clean fuel production tax credit. Agency lawyers are listening to proposals by more than 70 groups for…
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Columbia Tax Policy Conference
Columbia Law School: Tax Policy Conference Sponsored by The Charles E. Gerber Transactional Studies Center and Davis Polk & Wardwell (May 28-29, 2026):
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Saez and Zucman: The Case for California’s Billionaire Wealth Tax
Emmanuel Saez (Berkeley-Economics) and Gabriel Zucman (Paris School of Economics) have published a guest essay in the New York Times: “The Case for California’s Billionaire Wealth Tax.” From the article: On taxes and much else, California has often led the country. In 1978 the state’s voters approved Proposition 13, which strongly limited tax increases. Prop…
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Eleventh Annual Texas Tax Faculty Workshop
On May 19, Baylor Law School hosted the Eleventh Annual Texas Tax Faculty Workshop: Also in attendance were Eric Reis (UNT Dallas) and Rita Julien (Houston).
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Harpaz Presents “Towards a Theory of Tax Sovereignty” at UNLV
Assaf Harpaz (Georgia) will be presenting his article “Toward a Theory of Tax Sovereignty” at the National Business Law Scholars Conference 2026, as part of the panel on Tax Theory & Policy. The conference is hosted by the William S. Boyd School of Law at the University of Nevada, Las Vegas. Here’s the abstract of…
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Angrist et al on University Endowment Taxation and Scientific Progress
Joshua Angrist (MIT), Marc Diederichs (Passau) & Glenn Ellison (MIT) have a new NBER working paper, “Will The University Endowment Tax Slow Scientific Progress? Evidence from Elite Economics PhD Programs.” Here is the abstract: The 2025 university endowment tax hike and other sources of financial pressure may lead the schools that train the most prolific…
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Boll, Saez, and Zucman on California Billionaires
Jasper Boll (Paris School of Economics), Emmanuel Saez (Berkeley), and Gabriel Zucman (PSE and Berkeley) have a new NBER working paper, “California Billionaires: Wealth, Taxes, and Wealth Tax Revenue Estimates.” Here is the abstract: This paper documents the wealth of California’s billionaires and the taxes they pay. California billionaires’ wealth exceeds $2 trillion today, the…
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Avi-Yonah on the Revival of Economic Substance
Reuven Avi-Yonah (Michigan), “Liberty Global and the Revival of Economic Substance” (Tax Notes, May 25, 2026): On April 21 the Tenth Circuit issued its long-awaited opinion in Liberty Global. By a 2-1 majority, the panel upheld the decision of the district court that a tax shelter used by Liberty Global had to be disregarded under…
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Bloomberg: “Democrats’ 100% Tax Plan on Fund Payouts Zeroes In on GOP Angst”
Chris Cioffi (Bloomberg Law): Democrats’ 100% Tax Plan on Fund Payouts Zeroes In on GOP Angst Democrats are trying to force the GOP’s hand by introducing a 100% tax on payments from the Justice Department’s new fund for victims of government weaponization, even as Republicans face increasing pressure on what’s become a politically toxic $1.8 billion…
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Crypto Asset Tax Legislation Progressing
Katie Lobosco (Tax Analysts): Bipartisan Crypto Tax Bill Introduced After Months of Discussion A bipartisan duo of House taxwriters introduced a bill that would address the way digital assets are taxed in an attempt to make it easier for consumers and investors to use digital payment technology. House Ways and Means Committee members Max L. Miller, R-Ohio,…
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Costco Fights Tariff Refund Class Action Suit
Natalie Olivo (Bloomberg Law): Costco Calls Suit Over Tariff Refunds Premature Costco urged an Illinois federal court to toss a putative consumer class action seeking to recoup the higher costs that shoppers paid under President Donald Trump’s global tariffs, contending that the case is premature in the wake of uncertain corporate refunds.
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Pittsburgh Tax Review | ATPI Symposium: Gender & Tax
The Pittsburgh Tax Review has published Vol. 23, No. 1 (2025): ATPI Symposium on Gender & Tax, 23 Pitt. Tax Rev. 1-281 (2025):
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Trump’s Surgeon General Pick Also Is a Farmer for Tax Purposes
Daniel Han, Nicole Saphier Is Trump’s Pick for Surgeon General. She’s Also a ‘Farmer’ in New Jersey—and Gets a Tax Break, Politico (May 21, 2026):
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Law360’s Jobs Data by Law School—Including BigLaw and Federal Clerkships
Following up on Kevin Johnson’s post on the best law schools for BigLaw jobs, Law360 has its updated employment analysis for Class of 2025 law school graduates. The highlights: school-by-school data on BigLaw placement, clerkships, public interest jobs, government jobs, and jobs in business or industry. Top-ten lists for BigLaw and federal clerkships, as well…
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IFS Working Paper: Discretion Versus Algorithms
Justine Knebelmann, Victor Pouliquen & Bassirou Sarr, Discretion Versus Algorithms: Bureaucrats, Tax Equity and Acceptability, Inst. Fisc. Stud. Working Paper 26/34 (May 11, 2026):
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Brookings: Can Taxes Alone Fix Long-Term Deficits?
The Brookings Institution has two commentaries that draw on Jessica Riedl, Spending, Taxes, and Deficits: A Book of Charts, Brookings Inst. (April 2026). The first deals with taxes as a solution to long-term deficits, and the second addresses the short-lived balanced budget of the late Clinton years. Links and two charts, below the fold.
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SSRN Review & Roundup: Harpaz Reviews Pratt’s Aligning Reparations and Taxation
This week, Assaf Harpaz (Georgia; Google Scholar) reviews a new work by Katherine Pratt (Loyola LA; Google Scholar), Aligning Reparations and Taxation, Wm. & Mary J. Race, Gender & Soc. Just. (forthcoming). In Aligning Reparations and Taxation, the author makes an exceptional contribution to the tax literature by examining the nontaxation of reparation remedies. Absent…
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Liscow (NY Times): The Simple Answer to Taxing the Rich Is the Best Answer
Zachary Liscow, The Simple Answer to Taxing the Rich Is the Best Answer (New York Times, May 22, 2026) The United States is seeing an increasing concentration of wealth at the very top and a worsening national debt. For many Americans, taxing the rich more is an obvious move. Ask tax policy experts how to…