Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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Three Intersections of Taxpayer Privacy and the IRS
In a system predicated on voluntary compliance, taxpayer privacy is an evergreen concern. But in recent weeks, three disparate events have raised questions about the security of taxpayer data—and what information the government should collect through the tax system. What are these events? First, the Treasury Inspector General for Tax Administration’s report on IRS employees’…
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Washington & Lee Requires AI Training Before 1L Classes Begin
Washington & Lee University School of Law has introduced a mandatory, one-credit course on ethical and effective AI use. The course is built around Harvey—which recently raised $550 million at a $15.5 billion valuation that’s quintupled since February 2025—and reaches students “[b]efore they read their first case or step into their first doctrinal classroom.” That…
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Parada Posts Four International Tax Articles on SSRN
Leopoldo Parada (King’s College London) has posted four previously published articles on SSRN that address recurring questions in international and EU tax law. All originally appeared in Multinational Group Tax & Transfer Pricing News. Topics range from GloBE to digital services taxes to the Pandora Papers to state aid. Taken together, this batch of Parada’s…
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WSJ on Mortgage Rates (and Tax Savings) with the Bank of Mom and Dad
In the Wall Street Journal, Laura Saunders refreshes well-traveled techniques for intergenerational wealth transfers beyond the ultrawealthy. Many of these involve helping younger generations buy homes. Saunders’ advice is timely, as conventional home mortgage rates hit a three-year high. (October’s AFR isn’t exactly channelling the Obama years, either, but gifts and itemized deductions may reduce…
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SSRN Review & Roundup: Saito Reviews Appleby’s Constitutional Commandeering
This week, Blaine Saito (Ohio State) reviews a new work by Andrew D. Appleby (Tennessee), Constitutional Commandeering, 62 Wake Forest L. Rev. 1 (2026). Federalism requires that our several states be able to raise revenue to undertake key functions. Indeed, most government services and regulation happen at the state and local level. But when can…
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Bloomberg: Ireland Plans More Changes to R&D Tax Credit, IP Incentives
Bloomberg (Ryan Hogg), Ireland Plans More Changes to R&D Tax Credit, IP Incentives: Ireland plans to expand its research and development tax credit and extend refunds on intellectual property profits as part of its upcoming budget presented Tuesday. Tanaiste and Finance Minister Simon Harris also announced changes to withholding taxes and promised the implementation of…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 71 (September 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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ABA Tax Section: Tax and Democracy Symposium
The ABA Tax Section and Northwestern Pritzker School of Law’s Tax Program are hosting the Tax and Democracy Symposium on October 15, 2026, both in person and online. To be held October 15, 2026, at the Northwestern Pritzker School of Law campus in Chicago, the 2026 Tax & Democracy Symposium will bring together academics, students…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 70 (September 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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Section 351 Exchanges and ETFs
In Matt Levine’s Money Stuff newsletter from September 29, he highlights IRS Rev. Rul. 2026-20, which targets the use of section 351 in the context of exchange traded funds (ETFs). Here’s how Levine describes the so-called “heartbeat” transactions: The reason this works is that ETFs qualify as regulated investment companies, and as such, under section…
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Clarke Presents “Firms, Individuals, and the Income Distribution” Today at Missouri
Conor Clarke (Wash U) will present Firms, Individuals, and the Income Distribution, coauthored with Wojciech Kopczuk (Columbia), 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 open to guest participants via Zoom. Anyone who would like to join as a…
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Taxing Entrepreneurial Wealth: Evidence from Norway
Marius Ring (Texas) has a new NBER working paper, “Taxing Entrepreneurial Wealth: Evidence from Norway, 2021–2025.” Here is the abstract: Whether imposing higher taxes on business owners adversely affects business activity by constraining investment and inducing capitalist flight is a central question in the ongoing debate on how to tax the ultra wealthy. To shed…
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Graetz on the New IRS Regulations to Revoke Tax-Exempt Status
Michael Graetz has a new piece on the proposed IRS regulations, “A Presidential Assault on Pluralistic Democracy: The IRS’s Attack on Private Schools” (Tax Notes, Sept. 18, 2026). I believe the full text is not behind a paywall. Here’s how it starts: On September 4 the IRS published proposed regulations (REG-119986-25) that, if finalized, would…
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Maher Presents “On the Securitization of Residential Real Property” Today at Pepperdine
Luke Maher (Seattle), presents On the Securitization of Residential Real Property or Wealth Taxation as Penalty 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 our post-workshop lunch), please contact Deanna Newton. Update: Post-workshop lunch:
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Zelinsky: Why New York’s Pied-à-Terre Tax Is Unconstitutional
Edward Zelinsky (Cardozo): Why New York’s Pied-à-Terre Tax Is Unconstitutional, 122 Tax Notes State 29 (Oct. 5, 2026) Judicial review of tax laws under the equal protection clause of the U.S. Constitution is limited. But even under this forgiving standard, New York City’s pied-à-terre property tax surcharge on expensive second homes is unconstitutional because it…
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Wilbur Ross, Steve Wynn Sue Over New York Pied-a-Terre Tax
Chris Dolmetsch & Laura Nahmias (Bloomberg Law): Wilbur Ross, Steve Wynn Sue Over New York Pied-a-Terre Tax Former US Commerce Secretary Wilbur Ross and casino tycoon Steve Wynn filed a lawsuit challenging New York’s pied-à-terre tax, saying that it’s unconstitutional because it only targets people who live outside the city.
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Bearer-Friend Presents “The AI Equity Tax: Past, Present, and Future” Today at Boston University
Jeremy Bearer-Friend (George Washington) presents The AI Equity Tax: Past, Present, and Future today from 1-2pm ET at Boston University, as part of the Graduate Tax Program’s Tax Policy Guest Speaker series. Registration is available by emailing gradtax@bu.edu. As the scope and impact of the AI industry continue to grow, so too does the import of…
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Hemel: Ordinary Loss Harvesting — A Tax Shelter of Treasury’s Own Making
Daniel J. Hemel (NYU), Ordinary Loss Harvesting: A Tax Shelter of Treasury’s Own Making, 192 Tax Notes Fed. 2191 (Sept. 21, 2026): Tax loss harvesting typically allows investors to generate capital losses that they can use to offset capital gains and up to $3,000 per year in ordinary income. A new type of tax-aware strategy…
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IRS Revokes 71 Pieces of Tax Guidance; Tax Pros Wrangle With Treasury Rule Authority Post-Loper Bright
Bloomberg Law, IRS Revokes 71 Pieces of Tax Guidance, Calling Them Obsolete: The IRS revoked 71 pieces of guidance that it says are obsolete as part of President Donald Trump’s push for deregulation. The revoked revenue rulings, revenue procedures, notices, and other documents “no longer provide useful information,” the IRS said in a notice Tuesday…
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Treasury Follows Through on “Too Good to Be True” ETF Tax Strategies
In July, Treasury officials warned that they were scrutinizing a burgeoning category of tax-aware investment strategies. At the time, Treasury stopped short of issuing guidance. Well, the agency now has taken the “first concrete steps” to curtail these novel financial products. At the end of September, Treasury and the IRS released Notice 2026-62, a broad…
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Johannesen et al.: Does Global Financial Transparency Improve Tax Compliance in Developing Countries?
Niels Johannesen (Oxford, Saïd Bus. Sch.), Lauge Larsen (Danish Ministry Tax’n) & Nadine Riedel (U. Münster, Inst. Pub. & Regional Econ.), Does Global Financial Transparency Improve Tax Compliance in Developing Countries?, CESifo Working Paper No. 12747 (June 2026): In a coordinated effort to curb tax evasion, governments systematically exchange information about bank accounts with foreign…
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WSJ: Hedge-Fund Managers Lose Out on Lucrative Tax Strategy
After the Second Circuit’s decision in Soroban and the Fifth Circuit’s substituted opinion in Sirius Solutions, the limited partner exception for self-employment taxes is narrower. With the First Circuit’s decision in Denham Capital Management still to come, the odds of a Supreme Court ruling on the issue are lower. While there’s some doctrinal gap between…
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SSRN Review & Roundup: Harpaz Reviews Raskolnikov’s Taxation and Formal Equality
This week, Assaf Harpaz (Georgia; Google Scholar) reviews a new work by Alex Raskolnikov (Columbia; Google Scholar), Taxation and Formal Equality, 104 Wash. U. L. Rev. __ (forthcoming 2027). Most modern capitalist democracies embody the idea that law should be formally equal, making no formal distinction based on individuals’ material resources. In this insightful and…
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Kathleen Thomas (UNC) Presents “Taxing Attention” at Boston College Tax Policy Workshop
Kathleen Thomas (UNC Law) presents “Taxing Attention” at Boston College Tax Policy Workshop today: The rise of social media platforms and other digital businesses has transformed the economy. Companies like Meta and Alphabet have developed a booming industry where advertising revenue drives profits and we, the consumers, provide the product. But what, exactly, are we…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 69 (September 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron: