Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Weekly SSRN Roundup
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SSRN Review & Roundup: Gordon Reviews Hemel & Kern’s Separation of Bases and the Fiscal Constitution
This week, Jeff Gordon (Vanderbilt, Google Scholar) reviews Daniel Hemel (NYU, Google Scholar) and Adam Kern (University of San Diego, Google Scholar), Separation of Bases and the Fiscal Constitution, 105 Tex. L. Rev. _ (forthcoming 2027). Daniel Hemel and Adam Kern have written an ambitious article that aims to reshape our understanding of the relationship
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SSRN Review & Roundup: Eyal Reviews Bank’s High Rates and Low Taxes
This week, Mirit Eyal (Alabama; Google Scholar) reviews Steven A. Bank (UCLA; SSRN), Introduction, High Rates and Low Taxes: Tax Dodging in Mid-Century America (Cambridge University Press 2026). A word of full disclosure before we begin. Steven Bank was my doctoral advisor and mentor, and it is entirely possible, indeed more than likely, that I
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SSRN Review & Roundup: Elkins Reviews Brauner’s Income and Territoriality
This week, David Elkins (Netanya; Google Scholar) reviews a new work by Yariv Brauner (Florida; Google Scholar), Income and Territoriality: A Purpose-Based Reform of Income Sourcing Rules, _ Can. Tax J. _ (forthcoming 2026): It is commonly noted in the literature on international taxation that the international tax regime instituted in the wake of the
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SSRN Review & Roundup: Marks Reviews Georgakopoulos, Tarkington & Crawford’s Spousal Economic Abuse: Tax Complicity and Solutions
This week, Noah H. Marks (UNC) reviews a new article by Nicholas L. Georgakopoulos (Indiana), Margaret Tarkington (Indiana), and Bridget Crawford (Pace), Spousal Economic Abuse: Tax Complicity and Solutions (Feb. 11, 2026). The fact that the income tax system allows—and, indeed, encourages—married couples to file a joint tax return reporting pooled income is too often
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SSRN Review & Roundup: Speck Reviews Mann and Roberts’s The Long and Winding Road
This week, Sloan Speck (Colorado, Google Scholar) reviews a new work by Roberta F. Mann (Oregon, SSRN) & Tracey M. Roberts (Samford, Google Scholar), The Long and Winding Road: The Inflation Reduction Act’s Energy and Environmental Tax Credits, 78 Nat’l Tax J. 223 (2025) (download here). The Inflation Reduction Act of 2022 introduced a generational
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SSRN Review & Roundup: Saito Reviews Noked, Kim & Avi-Yonah’s How the U.S. Constitution Shapes International Tax Law
This week, Blaine Saito (Ohio State, Google Scholar) reviews a new work by Noam Noked (CUHK, Google Scholar), Young Ran (Christine) Kim (Cardozo, Google Scholar) & Reuven S. Avi-Yonah (Michigan, Google Scholar), How the U.S. Constitution Shapes International Tax Law: Instrument Choice in Tax Agreements (Feb. 26, 2026). The United States has not ratified a major new tax treaty
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SSRN Review & Roundup: Harpaz Reviews Gamage & Maynard’s Confronting the Tax-and-Oligarchy Catch-22
This week, Assaf Harpaz (Georgia; Google Scholar) reviews a new work by David Gamage (Missouri; Google Scholar) and Goldburn Maynard Jr. (Connecticut; Google Scholar), Confronting the Tax-and-Oligarchy Catch-22, U. Ill. L. Rev. (forthcoming). Taxes on wealth are among the most widely debated tax policies in the U.S. and abroad, frequently invoked by policymakers as a
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SSRN Review & Roundup: Narotzki Reviews Thomas’s Taxing Attention
This week, Doron Narotzki (Akron; Google Scholar) reviews Kathleen DeLaney Thomas (UNC; Google Scholar), Taxing Attention, Emory L.J. (forthcoming). Thomas offers an important contribution to one of the most difficult tax debates created by the digital economy. For years, much of the legal and tax literature has treated data as the core commodity exchanged when
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SSRN Review & Roundup: Eyal Reviews Harpaz’s Taxing AI
This week, Mirit Eyal (Alabama; Google Scholar) reviews a new work by Assaf Harpaz (Georgia; Google Scholar), Taxing AI, B.U. L. Rev. __ (forthcoming 2026): Artificial intelligence is no longer a distant prospect confined to science fiction or academic speculation. It is now reshaping industries, displacing workers, and concentrating wealth at an unprecedented pace. The
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SSRN Review & Roundup: Gordon Reviews Love’s Taxing Complexity
This week, Jeff Gordon (Vanderbilt, Google Scholar) reviews a new work by Michael Love (Columbia, Google Scholar), Taxing Complexity (2026): Tax scholars may be generally familiar with the difficulty the IRS faces in auditing sophisticated taxpayers with complex tax positions, but the scale of the problem is shocking even to this cynical reader. As Michael
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SSRN Review & Roundup: Elkins Reviews Fox, Liscow & Love’s How to Tax Business?
This week, David Elkins (Netanya; Google Scholar) reviews Edward G. Fox (Michigan; Google Scholar), Zachary D. Liscow (Yale; Google Scholar) & Michael Love (Columbia; Google Scholar), How to Tax Business? Economic Rents, Legibility, and the Corporate-Pass-Through Divide (2026): The dilemma of whether to tax income earned via an entity at the entity level or to
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SSRN Review & Roundup: Marks Reviews Drumbl’s Poverty, Fresh Starts, and the Social Safety Net
This week, Noah H. Marks (UNC) reviews a new work by Michelle L. Drumbl (Washington & Lee), Poverty, Fresh Starts, and the Social Safety Net, 98 Temple L. Rev. 57 (2025): From the outside, the interface between federal income tax law and bankruptcy law (itself a combination of federal and state law) is a technical
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SSRN Review & Roundup: Speck Reviews Gribnau’s Developing Sustainable Corporate Tax Governance
This week, Sloan Speck (Colorado) reviews a new work by Hans Gribnau (Tilburg L. Sch.), Developing Sustainable Corporate Tax Governance, in A Journey Through European and International Taxation 125 (2024) (posted to SSRN on February 3, 2026). Taxes are embedded—tacitly and explicitly—in current debates about sustainable economic development. In Developing Sustainable Corporate Tax Governance, Hans
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SSRN Review & Roundup: Eyal Reviews Mazur’s Modernizing the IRS in the Age of AI
This week, Mirit Eyal (Alabama; Google Scholar) reviews Orly Mazur (SMU, Google Scholar), Modernizing the IRS in the Age of AI, 45 Va. Tax Rev. 182 (2025): Artificial intelligence (“AI”) is no longer an experimental technology confined to labs and tech firms. It is shaping government operations in real time. Federal agencies are deploying generative
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SSRN Review & Roundup: Harpaz Reviews Eyal’s Taxation as Public Hedging
This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Mirit Eyal (Alabama, Google Scholar), Taxation as Public Hedging (Jan. 20, 2026). Tax systems regulate taxpayer behavior by offering credits, deductions, exemptions, and exclusions for activities deemed socially favorable. In Taxation as Public Hedging, the author suggests that tax expenditures can also be
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SSRN Review & Roundup: Narotzki Reviews McGee, Yuzbasi, Kisa & Benk’s The Role of Emotions in Tax Evasion
This week, Doron Narotzki (Akron; Google Scholar) reviews Robert W. McGee (Fayetteville State University), Bahadir Yuzbasi (Inonu University), Ökkes Kisa (Inonu University) & Serkan Benk (Inonu University), The Role of Emotions in Attitudes Toward Ethics of Tax Evasion: An Empirical Study, 10 Int’l J. Pub. Fin. 325 (2025). McGee, Yuzbası, Kısa, and Benk offer a
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SSRN Review & Roundup: Saito Reviews Repetti’s Private Equity, Health Calamity
This week, Blaine Saito (Ohio State) reviews a new work by James R. Repetti (Boston College), Private Equity, Health Calamity: How Our Tax Laws Aid Private Equity Investment in Hospitals and Nursing Homes (Dec. 15, 2025): The reach of private equity (PE) continues to expand into nearly every sector of the American economy. For example, the Trump
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SSRN Review & Roundup: Elkins Reviews Roberts’s W(h)ither Regulation? Hither to the Tax System
This week, David Elkins (Netanya) reviews a new work by Tracey M. Roberts (Samford), W(h)ither Regulation? Hither to the Tax System, 43 Pace Env’r L. Rev. __ (forthcoming 2025): Administrative law has undergone something of a sea change over the past few years. In a number of key cases, the Supreme Court established new doctrines
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SSRN Review & Roundup: Endean Reviews Libby’s Tax-Exemption and the Shadow of the Law
This week, Jon Endean (Brooklyn) reviews a new work by Lauren Libby (Yale, moving to Texas), Tax-Exemption and the Shadow of Law (Nov. 28, 2025). One of the many tools that the Trump administration has used (or at least, threatened to use) is the ability of the IRS to deny or revoke an organization’s tax
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SSRN Review & Roundup: Speck Reviews Belnap, Hoopes & Hadfield’s Does Voluntary Private Tax Disclosure Reduce IRS Audit Risk?
This week, Sloan Speck (Colorado) reviews a new work by Andrew Belnap (U. Texas, McCombs Sch. Bus.), Jeffrey L. Hoopes (UNC, Accounting) & Read Hadfield (U. Texas, McCombs Sch. Bus.), Does Voluntary Private Tax Disclosure Reduce IRS Audit Risk? (Sept. 30, 2025). As a formal matter, IRS private letter rulings provide legal certainty to specific
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SSRN Review & Roundup: Endean Reviews Zhang’s The Other Taxation
This week, Jon Endean (Brooklyn) reviews a new work by Alex Zhang (Emory), The Other Taxation: Tribes, Territories, and Fiscal Autonomy, 126 Colum. L. Rev. __ (forthcoming 2026). In his article about the taxation of Native American tribes and U.S. territories, Alex Zhang makes several important contributions to the literature. Native American tribes and U.S.
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SSRN Review & Roundup: Speck Reviews Silver’s The Tax Insurance Trap
This week, Sloan Speck (Colorado) reviews a new work by Benjamin Silver, The Tax Insurance Trap, 2026 Wis. L. Rev. __ (forthcoming). Since the early 2000s, the tax insurance industry has boomed. Today, tax insurance is commonplace, covering risks from tax status violations to adverse transactional treatment with policy limits into the billions. In a
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SSRN Review & Roundup: Saito Reviews Walker’s The Durability of Tax Laws and Their Objectives
This week, Blaine Saito (Ohio State, Google Scholar) reviews a new work by Alexandra Ferrara Walker (NYU), The Durability of Tax Laws and Their Objectives, 80 Tax L. Rev. ___ (forthcoming 2026). What makes a law obsolete? Alexandra Ferrara Walker’s piece The Durability of Tax Laws and Their Objectives offers a compelling framework for understanding
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SSRN Review & Roundup: Harpaz Reviews Bearer-Friend & Polcz’s Sharing the Algorithm
This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Jeremy Bearer-Friend and Sarah Polcz, Sharing the Algorithm: The Tax Solution to Generative AI, 17 Colum. J. Tax L. __ (forthcoming 2025). The rapid integration of Artificial Intelligence (AI) threatens to destabilize labor patterns and develop market monopolies with extreme concentrations of wealth.
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews Hasen’s Pricing Low-Income Resource Volatility
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by David Hasen (Florida), Pricing Low-Income Resource Volatility. Economists and policymakers historically have approached households as static constructs, governed by rhetorics of persistent poverty or a linear trajectory of upward mobility. This perspective is complicated by current research that emphasizes contingency and precarity as