Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Weekly SSRN Roundup
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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
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Weekly SSRN Tax Article Review And Roundup: Kim Reviews Schön’s International Tax Scholarship And International Tax Activism
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews a recent article by Wolfgang Schön (Max Planck), International Tax Scholarship and International Tax Activism (August 2024). While writing a scholarly article, tax scholars sometimes develop an idea based on their personal experience or political stance in addition to a pure scientific, doctrinal
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Weekly SSRN Tax Article Review And Roundup: Kim Reviews Schön’s International Tax Scholarship And International Tax Activism
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews a recent article by Wolfgang Schön (Max Planck), International Tax Scholarship and International Tax Activism (August 2024). While writing a scholarly article, tax scholars sometimes develop an idea based on their personal experience or political stance in addition to a pure scientific, doctrinal
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Weisbach’s An APA For Tax
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews a new work by David A. Weisbach (Chicago; Google Scholar), An APA For Tax. The Administrative Procedure Act (APA) is a cornerstone of administrative law in the United States, providing a framework for the procedures and processes that federal agencies must follow. Its relevance to tax law has become increasingly
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews Weisbach’s An APA For Tax
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews a new work by David A. Weisbach (Chicago; Google Scholar), An APA For Tax. The Administrative Procedure Act (APA) is a cornerstone of administrative law in the United States, providing a framework for the procedures and processes that federal agencies must follow. Its relevance to tax law has become increasingly
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Oei’s Disentangling Power And Preferences In Tax Treaties Between Developing And OECD Countries
This week, David Elkins (Netanya, Google Scholar) reviews a new work by Shu-Yi Oei (Duke; Google Scholar), Disentangling Power and Preferences in Tax Treaties between Developing and OECD Countries Using Multilevel Modeling. One of the linchpins of the international tax regime is the network of over 3,000 bilateral tax treaties. Of those, as noted by Prof.
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Oei’s Disentangling Power And Preferences In Tax Treaties Between Developing And OECD Countries
This week, David Elkins (Netanya, Google Scholar) reviews a new work by Shu-Yi Oei (Duke; Google Scholar), Disentangling Power and Preferences in Tax Treaties between Developing and OECD Countries Using Multilevel Modeling. One of the linchpins of the international tax regime is the network of over 3,000 bilateral tax treaties. Of those, as noted by Prof.
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews Chaim’s The Common Ownership Tax Strategy
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Danielle A. Chaim (Bar-Ilan; Google Scholar), The Common Ownership Tax Strategy, 101 Wash. U. L. Rev. 501 (2023). Over the last decade-and-a-half, economists and corporate law scholars have unpacked the consequences of index-based mutual funds’ burgeoning ownership of equity in public companies. In The
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews Chaim’s The Common Ownership Tax Strategy
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Danielle A. Chaim (Bar-Ilan; Google Scholar), The Common Ownership Tax Strategy, 101 Wash. U. L. Rev. 501 (2023). Over the last decade-and-a-half, economists and corporate law scholars have unpacked the consequences of index-based mutual funds’ burgeoning ownership of equity in public companies. In The
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews The Conflictual Core Of Global Tax Cooperation By Oei & Ring
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Diane M. Ring (Boston College; Google Scholar) & Shu-Yi Oei (Duke; Google Scholar), The Conflictual Core of Global Tax Cooperation. In Momentum has grown around Pillar Two created through the OECD/G20’s inclusive framework. But this growing moment of unity masks the conflict between developed
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews The Conflictual Core Of Global Tax Cooperation By Oei & Ring
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Diane M. Ring (Boston College; Google Scholar) & Shu-Yi Oei (Duke; Google Scholar), The Conflictual Core of Global Tax Cooperation. In Momentum has grown around Pillar Two created through the OECD/G20’s inclusive framework. But this growing moment of unity masks the conflict between developed
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Weekly SSRN Tax Article Review And Roundup: Layser Reviews Shanske’s The Future Of SALT
This week, Michelle Layser (San Diego; Google Scholar) reviews Darien Shanske (UC-Davis; Google Scholar), The Future of SALT (?): Using and Improving Formulas for Apportioning Income, Residence and Intangibles, 78 Tax Law. __ (2025). Formulas are a common feature of state tax law. The quintessential example is the formulary apportionment of income earned by multistate
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Weekly SSRN Tax Article Review And Roundup: Layser Reviews Shanske’s The Future Of SALT
This week, Michelle Layser (San Diego; Google Scholar) reviews Darien Shanske (UC-Davis; Google Scholar), The Future of SALT (?): Using and Improving Formulas for Apportioning Income, Residence and Intangibles, 78 Tax Law. __ (2025). Formulas are a common feature of state tax law. The quintessential example is the formulary apportionment of income earned by multistate
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Weekly SSRN Tax Article Review And Roundup: Narotzki Reviews Utke’s There Is No Carried Interest Loophole
This week, Doron Narotzki (Akron; Google Scholar) reviews Steve Utke (Connecticut; Google Scholar), There is No Carried Interest Loophole. Steven Utke's paper presents a unique argument against the widespread criticism of the tax treatment of carried interest. Commonly referred to by many (including myself) as a "loophole," carried interest essentially allows private equity (“PE”) and
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Weekly SSRN Tax Article Review And Roundup: Narotzki Reviews Utke’s There Is No Carried Interest Loophole
This week, Doron Narotzki (Akron; Google Scholar) reviews Steve Utke (Connecticut; Google Scholar), There is No Carried Interest Loophole. Steven Utke's paper presents a unique argument against the widespread criticism of the tax treatment of carried interest. Commonly referred to by many (including myself) as a "loophole," carried interest essentially allows private equity (“PE”) and
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Weekly SSRN Tax Article Review And Roundup: Kim Reviews Pillar One And Mobility – A Truly Global Solution? By Kostić & Navarro
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews Svetislav Kostić (University of Belgrade Law School; Google Scholar) and Aitor Navarro (Max Planck Institute for Tax Law and Public Finance; Google Scholar)’s recent paper, Pillar One and Mobility – A Truly Global Solution?, 51 Intertax 840 (2023). The multilateral instrument to implement Pillar
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Weekly SSRN Tax Article Review And Roundup: Kim Reviews Pillar One And Mobility – A Truly Global Solution? By Kostić & Navarro
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews Svetislav Kostić (University of Belgrade Law School; Google Scholar) and Aitor Navarro (Max Planck Institute for Tax Law and Public Finance; Google Scholar)’s recent paper, Pillar One and Mobility – A Truly Global Solution?, 51 Intertax 840 (2023). The multilateral instrument to implement Pillar
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews An Originalist Analysis Of Wealth Taxes Under The Constitution By Schizer & Calabresi
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews David M. Schizer (Columbia) & Steven G. Calabresi (Northwestern), Wealth Taxes Under the Constitution: An Originalist Analysis, 28 Fla. Tax Rev. ___ (2024). This Article delivers a timely and persuasive originalist examination of the federal wealth tax’s constitutionality, particularly relevant given the recent national and international initiatives to
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Weekly SSRN Tax Article Review And Roundup: Eyal-Cohen Reviews An Originalist Analysis Of Wealth Taxes Under The Constitution By Schizer & Calabresi
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews David M. Schizer (Columbia) & Steven G. Calabresi (Northwestern), Wealth Taxes Under the Constitution: An Originalist Analysis, 28 Fla. Tax Rev. ___ (2024). This Article delivers a timely and persuasive originalist examination of the federal wealth tax’s constitutionality, particularly relevant given the recent national and international initiatives to
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Reis’s The Gift Tax Treatment Of Loan Guarantees
This week, David Elkins (Netanya, Google Scholar) reviews Eric Reis (North Texas), Guaranteed Wealth? A New Way of Thinking About the Gift Tax Treatment of Loan Guarantees, 27 Fla. Tax Rev. _ (2024): In this week’s feature article, Professor Eric Reis examines the gift tax consequences of gratuitous loan guarantees. A prototypical example is one in
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Weekly SSRN Tax Article Review And Roundup: Elkins Reviews Reis’s The Gift Tax Treatment Of Loan Guarantees
This week, David Elkins (Netanya, Google Scholar) reviews Eric Reis (North Texas), Guaranteed Wealth? A New Way of Thinking About the Gift Tax Treatment of Loan Guarantees, 27 Fla. Tax Rev. _ (2024): In this week’s feature article, Professor Eric Reis examines the gift tax consequences of gratuitous loan guarantees. A prototypical example is one in
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews The TCJA: Sweeping Changes And An Uncertain Legacy By Gale, Hoopes & Pomerleau
This week, Sloan Speck (Colorado; Google Scholar) reviews William G. Gale (Brookings Institution; Google Scholar), Jeffrey L. Hoopes (North Carolina; Google Scholar) & Kyle Pomerleau (American Enterprise Institute), Sweeping Changes and an Uncertain Legacy: The Tax Cuts and Jobs Act of 2017, 39 J. Econ. Persp. __ (2024). Soon after the President signed the Tax
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Weekly SSRN Tax Article Review And Roundup: Speck Reviews The TCJA: Sweeping Changes And An Uncertain Legacy By Gale, Hoopes & Pomerleau
This week, Sloan Speck (Colorado; Google Scholar) reviews William G. Gale (Brookings Institution; Google Scholar), Jeffrey L. Hoopes (North Carolina; Google Scholar) & Kyle Pomerleau (American Enterprise Institute), Sweeping Changes and an Uncertain Legacy: The Tax Cuts and Jobs Act of 2017, 39 J. Econ. Persp. __ (2024). Soon after the President signed the Tax
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Competing Narratives On OIRA Review Of Tax Regulations By Hickman & Dooling
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Kristin E. Hickman (Minnesota; Google Scholar) & Bridget C.E. Dooling (Ohio State; Google Scholar), Competing Narratives in OIRA Review of Tax Regulations, 19 J.L. Econ. & Pol’y __ (2024): In 2023, the Biden Administration issued a Memorandum of Agreement (MOA) that exempted all tax regulations
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Weekly SSRN Tax Article Review And Roundup: Saito Reviews Competing Narratives On OIRA Review Of Tax Regulations By Hickman & Dooling
This week, Blaine Saito (Ohio State; Google Scholar) reviews a new work by Kristin E. Hickman (Minnesota; Google Scholar) & Bridget C.E. Dooling (Ohio State; Google Scholar), Competing Narratives in OIRA Review of Tax Regulations, 19 J.L. Econ. & Pol’y __ (2024): In 2023, the Biden Administration issued a Memorandum of Agreement (MOA) that exempted all tax regulations