Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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Call for Tax Papers and Panels: Law & Society Annual Meeting
Neil Buchanan has issued his annual call for tax papers and panels for next year’s annual meeting of the Law & Society Association in Chicago, Illinois (June 22–26, 2027): The Law & Society Association (LSA) will host its next Global Meeting from June 22 to 26, 2027, in Hong Kong. For the 23rd year in a row, I…
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NYU Law to Host Event on Loper Bright and the Future of Tax Administration
The Graduate Tax Program at the NYU School of Law is hosting two panels on how the Loper Bright decision might affect judicial deference to Treasury Regulations in the Greenberg Lounge of Vanderbilt Hall (40 Washington Square South, New York, NY) on Thursday, October 8, 2026, from 1:00–3:30pm, with a reception to follow. Panel 1:…
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Choi Presents “AI Deceleration (or Acceleration) by Taxation” Today at Missouri
Jonathan Choi (Wash U) will present AI Deceleration (or Acceleration) by Taxation, coauthored with Paul Connell (Wisconsin), 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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Foreign Tax Advantages after the Tax Cuts and Jobs Act
Anmol Bhandari and Ellen McGrattan (Minnesota) have a new NBER working paper, “Foreign Tax Advantages after the U.S. Tax Reform of 2017” (September 2026). Here is the abstract: We construct a firm-year panel of income-tax rate reconciliations from annual 10-K filings of public companies to study the effects of the Tax Cuts and Jobs Act…
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Evaluating Treasury’s Proposed Nondiscrimination Regs
Marie Sapirie has a new piece on the regs in Tax Notes, “Evaluating the Proposed Nondiscrimination Regs Under Bob Jones” (Sept. 28, 2026): The writing has been on the wall — or rather on Truth Social — for some time, but the IRS and Treasury finally released proposed regulations (REG-119986-25) on racial nondiscrimination in private…
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Jay Leno Hails California Crackdown on Supercar Tax Avoiders
Alicia Clanton & Hannah Elliott (Bloomberg Law): Jay Leno Hails California Crackdown on Supercar Tax Avoiders Jay Leno has amassed a legendary car collection and lent his name to a recent California law easing smog-check rules for some classics. But there’s one break for wealthy car owners he has little sympathy for: Montana license plates.…
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Not Worth the Wait: Reflections on the Maryland Digital Ad Tax Rulings
Darien Shanske (UC Davis), Michael Mazerov & Peter Enrich, Not Worth the Wait: Reflections on the Maryland Digital Ad Tax Rulings, 121 Tax Notes State 957 (Sept. 28, 2026) In this installment, the authors criticize the Maryland Tax Court’s three recent digital advertising tax decisions, arguing that they fail to even consider the differences between…
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Clarke & Marks: “Tax Exceptionalism After Loper Bright”
Conor Clarke (WashU) & Noah Marks (UNC), Tax Exceptionalism After Loper Bright, 192 Tax Notes Fed. 1963 (2026) We consider how tax regulations should be reviewed in a post-Chevron world. In 2011, the Supreme Court’s Mayo Foundation decision subjected Treasury regulations to ordinary Chevron deference, rejecting National Muffler’s tax-specific standard of review and declaring that the…
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Repetti Presents “How Our Tax Laws Aid Private Equity Investments in Hospitals and Nursing Homes” Today at Northwestern
James Repetti (BC) presents How Our Tax Laws Aid Private Equity Investments in Hospitals and Nursing Homes at Northwestern today as part of its Advanced Topics in Taxation Colloquium hosted by Ari Glogower: The social welfare impact of investments by Private Equity funds (PEs) in various sectors of our economy is mixed due to the…
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Justice Department Sides With Churches In Political Speech/Tax-Exempt Status Case
Bloomberg Law, Justice Department Sides With Churches in Political Speech Case: The Justice Department told an appeals court it largely agrees with the religious groups suing it over how far churches can wade into politics and still keep their tax-exempt status. The DOJ said a lower court judge was wrong to throw out an agreement…
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Like-Kind Exchanges on Mars and Beyond
Libin Zhang (Fried Frank, New York), Like-Kind Exchanges on Mars and Beyond, 192 Tax Notes Fed. 253 (July 13, 2026): On June 12, 2026, Space Exploration Technologies Corp. (SpaceX) went public in the largest IPO in history. While SpaceX’s artificial intelligence technologies account for $26.5 trillion (93%) of its $28.5 trillion total addressable market, the…
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WSJ: The IRS Is Cracking Down on a Favorite Way the Ultrawealthy Pass On Money
Grantor retained annuity trusts (GRATs) are a longstanding staple of high-end estate planning. The basic structure is well-traveled: a grantor transfers appreciating assets to an irrevocable trust, retains an annuity for a fixed term, and—if the assets outperform the rate on the annuity—shifts excess appreciation to beneficiaries with comparatively little gift-tax cost. In the Wall…
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The Law Schools Closest to the NYT’s Top 50 Restaurants for 2026
The New York Times recently published its annual list of the 50 best restaurants in America. The Times, however, did not address a crucial question for faculty, staff, and students: which law schools are closest to these esteemed eateries? This post fills that crucial gap. Notable culinary hotbeds: New York Law School is the proximate…
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Dyrda et al.: Global Ripple Effects of Corporate Tax Reforms
Sebastian Dyrda (Toronto, Dept. Econ.), Guangbin Hong (Michigan State, Dept. Econ.), Muhammad Ali Sajid (Toronto, Dept. Econ.) & Joseph B. Steinberg (Toronto, Dept. Econ.), Global Ripple Effects of Corporate Tax Reforms, NBER Working Paper No. 34627 (July 2026):
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Call for Papers: UNC & ATPI Tax Literacy Summit
UNC’s Tax Law Program and the American Tax Policy Institute have issued a Call for Papers for their Tax Literacy Summit, co-sponsored by the ABA Section of Taxation and the Pittsburgh Tax Review. The Summit will be April 8 and 9, 2027, in Washington, D.C., and papers will be published in a symposium issue of…
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SSRN Review & Roundup: Marks Reviews Cauble’s Guiding Tax Return Preparers Informally
This week, Noah H. Marks (UNC) reviews a new work by Emily Cauble (Wisconsin), Guiding Tax Return Preparers Informally, __ Fla. Tax Rev. __ (forthcoming). Slightly more than 50% of individual income tax returns are prepared by paid tax return preparers. While their credentials and experience vary, these advisors are generally seen as comparatively sophisticated…
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Bloomberg: Tax Group Calls Economic Substance Doctrine a Dangerous Tool
Bloomberg (James Matheson), Tax Group Calls Economic Substance Doctrine a ‘Dangerous Tool Courts must first determine the economic substance doctrine’s relevance to a transaction before the IRS can raise a challenge under it, a nonprofit taxpayer advocacy organization told the Fifth Circuit, warning of the government’s current “regulation by litigation” approach. The National Taxpayers Union…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 66 (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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The American Tax Policy Institute and the ABA Tax Section: NIL Taxation Seminars
Katie Pratt (Loyola Law School), Erin Henry (Arkansas), and Caroline Bruckner (American University) co-organized two seminars on the taxation of NIL Income co-sponsored with the American Tax Policy Institute and the ABA Tax Section:
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 65 (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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Mayer: The Future of Nonprofit Regulation in the United States
Lloyd H. Mayer (Notre Dame) has a new piece published, The Future of Nonprofit Regulation in the United States: Three Dynamic Trends, in the Nonprofit Policy Forum (Oct. 27, 2025). Here’s the abstract: Nonprofit regulation in the United States is strongly influenced by society-wide political trends. This influence is especially evident today with respect to racial justice debates,…
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Kim & Erokhin: Algorithmic Tax Ownership
Young Ran (Christine) Kim (Cardozo) and Dmitry Erokhin (Vienna University of Economics and Business) have a new piece, Algorithmic Tax Ownership, published in volume 51 of the BYU Law Review. Here’s the abstract: Tax ownership is a crucial concept for determining tax liabilities, compliance, and enforcement. However, neither the courts nor the IRS has provided clear…
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Second Circuit Affirms Tax Court’s Judgment in Soroban
In previous posts, I have highlighted the ongoing litigation over the term “limited partner,” as defined in section 1402(a)(13) (the so-called “limited partner exception”). The Fifth Circuit, in its decision last month in K Alain, LLLP v. Commissioner, held that “the ordinary public meaning of [the] phrase [“limited partner”] is a partner who plays no…
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Harpaz Presents “Tax Sovereignty” Today at Pepperdine
Assaf Harpaz (Georgia) will present Tax Sovereignty 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.
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Calderón Gómez and Kane Present “Pigou Goes Abroad” Today at Missouri
Luís C. Calderón Gómez (Cardozo) and Mitchell Kane (NYU) will present Pigou Goes Abroad (reviewed here by Jon Endean) 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…