Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Weekly SSRN Roundup
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Glogower’s The Constitutional Limits To The Taxing Power
This week, David Elkins (Netanya, Google Scholar) reviews Ari Glogower (Northwestern; Google Scholar), The Constitutional Limits to the Taxing Power, 93 Fordham L. Rev. 782 (2024). Moore v. United States, decided in June of this year, has sparked a renewed interest in Constitutional issues by tax scholars. Much of the discussion focuses on the issue of whether
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Glogower’s The Constitutional Limits To The Taxing Power
This week, David Elkins (Netanya, Google Scholar) reviews Ari Glogower (Northwestern; Google Scholar), The Constitutional Limits to the Taxing Power, 93 Fordham L. Rev. 782 (2024). Moore v. United States, decided in June of this year, has sparked a renewed interest in Constitutional issues by tax scholars. Much of the discussion focuses on the issue of whether
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews A Roadmap To NIL And Taxation By Narotzki & Brauner
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews a new work by Doron Narotzki (Akron; Google Scholar) and Yariv Brauner (Florida; Google Scholar), A Roadmap to NIL and Taxation, 14 Am. U. Bus. L. Rev. 1 (2024): The evolution of collegiate sports has significantly shifted following the emergence of Name, Image, and Likeness (NIL) policies. It
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews A Roadmap To NIL And Taxation By Narotzki & Brauner
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews a new work by Doron Narotzki (Akron; Google Scholar) and Yariv Brauner (Florida; Google Scholar), A Roadmap to NIL and Taxation, 14 Am. U. Bus. L. Rev. 1 (2024): The evolution of collegiate sports has significantly shifted following the emergence of Name, Image, and Likeness (NIL) policies. It
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Reconsidering Citizenship Taxation By Dagan & Mason
This week, Blaine Saito (Ohio State; Google Scholar) reviews Tsilly Dagan (Oxford; Google Scholar) & Ruth Mason (Virginia; Google Scholar), Reconsidering Citizenship Taxation, in Taxing People: The Next One Hundred Years (Tsilly Dagan & Ruth Mason, eds. Cambridge University Press 2025). There is truth to the hackneyed phrase that we live in a more globalized world. Tax discussions in recent
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Reconsidering Citizenship Taxation By Dagan & Mason
This week, Blaine Saito (Ohio State; Google Scholar) reviews Tsilly Dagan (Oxford; Google Scholar) & Ruth Mason (Virginia; Google Scholar), Reconsidering Citizenship Taxation, in Taxing People: The Next One Hundred Years (Tsilly Dagan & Ruth Mason, eds. Cambridge University Press 2025). There is truth to the hackneyed phrase that we live in a more globalized world. Tax discussions in recent
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Weekly SSRN Tax Article Review And Roundup: Layser Reviews Schaffa’s Reimagining The Employee Compensation Deduction
This week, Michelle Layser (San Diego; Google Scholar) reviews Daniel Schaffa (Richmond; Google Scholar), Reimagining the Deduction for Employee Compensation, 57 Mich. J. L. Reform 417 (2024). The deduction for employee compensation is among the most longstanding and least controversial deductions in the Tax Code. Unlike many deductions, which move the tax law away from a
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Weekly SSRN Tax Article Review And Roundup: Layser Reviews Schaffa’s Reimagining The Employee Compensation Deduction
This week, Michelle Layser (San Diego; Google Scholar) reviews Daniel Schaffa (Richmond; Google Scholar), Reimagining the Deduction for Employee Compensation, 57 Mich. J. L. Reform 417 (2024). The deduction for employee compensation is among the most longstanding and least controversial deductions in the Tax Code. Unlike many deductions, which move the tax law away from a
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Weekly SSRN Tax Article Review And Roundup: Kern Reviews Clausing’s The Green Transformation And Tax Policy Criteria
This week, Adam Kern (San Diego; Google Scholar) reviews an article by Kimberly Clausing (UCLA), The Green Transformation and Tax Policy Criteria. Climate change is an existential threat, and fiscal policy contains many of the tools for tackling it. But scholars of tax law have not given much attention to climate policy. (There are a
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Weekly SSRN Tax Article Review And Roundup: Kern Reviews Clausing’s The Green Transformation And Tax Policy Criteria
This week, Adam Kern (San Diego; Google Scholar) reviews an article by Kimberly Clausing (UCLA), The Green Transformation and Tax Policy Criteria. Climate change is an existential threat, and fiscal policy contains many of the tools for tackling it. But scholars of tax law have not given much attention to climate policy. (There are a
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Weekly SSRN Tax Article Review And Roundup: Narotzki Reviews The Effect Of Government Transparency On Corporate Tax Avoidance
This week, Doron Narotzki (Akron; Google Scholar) reviews The Effect of Government Transparency on Corporate Tax Avoidance: Evidence from State Freedom of Information Laws by Dongdi (Grace) Gu (University of Texas-Dallas), Jiapeng He (Chinese University of Hong Kong), Ying Huang (University of Texas-Dallas), and Ningzhong Li (University of Texas-Dallas). They say sunlight is the best disinfectant,
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Weekly SSRN Tax Article Review And Roundup: Narotzki Reviews The Effect Of Government Transparency On Corporate Tax Avoidance
This week, Doron Narotzki (Akron; Google Scholar) reviews The Effect of Government Transparency on Corporate Tax Avoidance: Evidence from State Freedom of Information Laws by Dongdi (Grace) Gu (University of Texas-Dallas), Jiapeng He (Chinese University of Hong Kong), Ying Huang (University of Texas-Dallas), and Ningzhong Li (University of Texas-Dallas). They say sunlight is the best disinfectant,
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Weekly SSRN Tax Article Review And Roundup: Kim Reviews Taxing The Wealthy At The State Level By Galle, Gamage & Shanske
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews a recent article by Brian D. Galle (Georgetown; Google Scholar), David Gamage (Missouri; Google Scholar), & Darien Shanske (UC-Davis; Google Scholar), Money Moves: Taxing the Wealthy at the State Level, 112 California L. Rev. __ (2025). While there are many tax reform proposals to tax
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Weekly SSRN Tax Article Review And Roundup: Kim Reviews Taxing The Wealthy At The State Level By Galle, Gamage & Shanske
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews a recent article by Brian D. Galle (Georgetown; Google Scholar), David Gamage (Missouri; Google Scholar), & Darien Shanske (UC-Davis; Google Scholar), Money Moves: Taxing the Wealthy at the State Level, 112 California L. Rev. __ (2025). While there are many tax reform proposals to tax
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews A Theory Of The REIT By Oh & Verstein
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Jason Oh (UCLA) & Andrew Verstein (UCLA; Google Scholar), A Theory of the REIT, 133 Yale L.J. 755 (2024). In A Theory of the REIT, Jason Oh and Andrew Verstein reconceptualize the connections between corporate law and tax law to illuminate the viability
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews A Theory Of The REIT By Oh & Verstein
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Jason Oh (UCLA) & Andrew Verstein (UCLA; Google Scholar), A Theory of the REIT, 133 Yale L.J. 755 (2024). In A Theory of the REIT, Jason Oh and Andrew Verstein reconceptualize the connections between corporate law and tax law to illuminate the viability
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Speck’s The Realization Rule As A Legal Standard
This week, David Elkins (Netanya, Google Scholar) reviews Sloan G. Speck (Colorado; Google Scholar), The Realization Rule as a Legal Standard, 16 Colum. J. Tax L. ___ (2024): Moore v. United States, decided by the Supreme Court in June of this year, reignited discussion about the concept of realization in the income tax. While statutory law
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Speck’s The Realization Rule As A Legal Standard
This week, David Elkins (Netanya, Google Scholar) reviews Sloan G. Speck (Colorado; Google Scholar), The Realization Rule as a Legal Standard, 16 Colum. J. Tax L. ___ (2024): Moore v. United States, decided by the Supreme Court in June of this year, reignited discussion about the concept of realization in the income tax. While statutory law
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews Osofsky’s Wellness And The Tax Law
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Leigh Osofsky (North Carolina; Google Scholar), Wellness and The Tax Law, 59 Ga. L. Rev. __ (2025). There is little doubt that the U.S. tax system’s patchwork treatment of medical care yields significant inequities, many of which reproduce broader problems with non-tax public health policy
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews Osofsky’s Wellness And The Tax Law
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Leigh Osofsky (North Carolina; Google Scholar), Wellness and The Tax Law, 59 Ga. L. Rev. __ (2025). There is little doubt that the U.S. tax system’s patchwork treatment of medical care yields significant inequities, many of which reproduce broader problems with non-tax public health policy
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Marks’s Winning By Losing: The Strategy Of Adverse Letter Rulings
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Noah Hertz Marks (Duke), Winning by Losing: The Strategy of Adverse Letter Rulings, 66 B.C. L. Rev. __ (2025). Tax law is rich with sources. We have sources of binding law in the forms of statutes, regulations, and court cases. But there
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Marks’s Winning By Losing: The Strategy Of Adverse Letter Rulings
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Noah Hertz Marks (Duke), Winning by Losing: The Strategy of Adverse Letter Rulings, 66 B.C. L. Rev. __ (2025). Tax law is rich with sources. We have sources of binding law in the forms of statutes, regulations, and court cases. But there
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Weekly SSRN Tax Article Review And Roundup: Kern Reviews Deferring Income With Tiered And Circular Partnerships By Sanchirico & Shuldiner
This week, Adam Kern (San Diego; Google Scholar) reviews an article by Chris William Sanchirico (Penn; Google Scholar) and Reed Shuldiner (Penn), Deferring Income with Tiered and Circular Partnerships. Taxes can be deferred when partnerships have different taxable years from their partners. A partnership might take account of its income in, say, January, while a
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Weekly SSRN Tax Article Review And Roundup: Kern Reviews Deferring Income With Tiered And Circular Partnerships By Sanchirico & Shuldiner
This week, Adam Kern (San Diego; Google Scholar) reviews an article by Chris William Sanchirico (Penn; Google Scholar) and Reed Shuldiner (Penn), Deferring Income with Tiered and Circular Partnerships. Taxes can be deferred when partnerships have different taxable years from their partners. A partnership might take account of its income in, say, January, while a
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Weekly SSRN Tax Article Review And Roundup: Narotzki Reviews Escajeda’s Bad Tax Policy Breeds Bad Blood Between Songwriters And Poets
This week, Doron Narotzki (Akron; Google Scholar) reviews an article by Hilary G. Escajeda (Mississippi College; Google Scholar), Bad Tax Policy Breeds Bad Blood Between Songwriters and Poets 183 Tax Notes Fed. 1625 (May 27, 2024). Escajeda offers a compelling and thought-provoking critique of the U.S. tax system’s treatment of artists, an area that is not