
Paul L. Caron
Dean
Pepperdine Caruso
School of Law

This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Michael S. Knoll (Penn; Google Scholar) Ruth Mason (Virginia; Google Scholar), and Wolfgang Schön (Max Planck), Regulatory Mismatches in the United States and the European Union. Interstate commercial actors often face regulatory mismatches, which refer to differences in legal regulations between states. Regulatory mismatches are…
This week, Doron Narotzki (Akron; Google Scholar) reviews a new work by Błażej Kuźniacki (Lazarski; Google Scholar) & Reuven S. Avi-Yonah (Michigan; Google Scholar), Rule of Law v. Rule of Power: US Tax Defense Measures in Light of the International Law of Countermeasures. In a time of growing tension and fragmentation in global trade and…
This week, Mirit Eyal (Alabama; Google Scholar) reviews a new work by Michael D. Guttentag (Loyola-L.A), The New Law and Inequality Scholarship, 105 B. U. L. Rev. 897 (2025). In recent decades, both legal and economic scholarship have largely converged on the view that redistribution can be pursued through the tax system rather than through substantive…
This week, Assaf Harpaz (Georgia, Google Scholar) reviews a new work by Rifat Azam (Interdisciplinary Center Herzliya; Google Scholar), The Global Minimum Tax and Intra Western Tax Competition, 44 Berkeley J. Int’l L. ___ (2026). Implementation of the OECD’s two-pillar solution, including the Global Minimum Tax, has been thrown into disarray following President Trump’s January 2025…
This week, Adam Kern (San Diego; Google Scholar) reviews Steve Rosenthal (Tax Policy Center) & Robert McClelland (Tax Policy Center; Google Scholar), Taxing Capital Gains at Death at a Rate Higher Than During Life, 186 Tax Notes Fed. 2417 (Mar. 31, 2025). In left-leaning tax policy circles, much energy has focused on taxing unrealized gains. There are…
This week, Doron Narotzki (Akron; Google Scholar) reviews a new paper by Jeffrey H. Kahn (Florida State) & Rebecca Roman (Gibson Dunn, Dallas), The Flip and Flop of Taxing Alimony, 16 Colum. J. Tax L. 131 (2025). Kahn and Roman’s article, The Flip and Flop of Taxing Alimony, offers a rigorous and well-structured analysis of…
This week, Mirit Eyal (Alabama; Google Scholar) reviews a new work by Lauren Libby (Ph.D. Candidate, Yale), Theories of University Endowment Taxation, 103 Wash. U. L. Rev. ___ (2025). Recent years have witnessed growing scrutiny over the role of wealth in higher education and increasing calls for greater financial accountability from elite universities. At the heart…
This week, David Elkins (Netanya, Google Scholar) reviews Tarcisio Diniz Magalhães (Antwerp; Google Scholar) & Allison Christians (McGill; Google Scholar), The Normative Shift in Corporate Tax Policy after GloBE, 17 World Tax J. ___ (2025): In this week’s feature article, Professors Magalhães and Christians argue that adoption of the OECD-led Global Anti-Base Erosion regime (commonly referred to by…
This week, Sloan Speck (Colorado; Google Scholar) reviews a new work by Clint Wallace (South Carolina; Google Scholar) & Bret Wells (Houston; Google Scholar), The Past and Future of Taxing "Incomes", 104 N.C. L. Rev. ___ (2025). The Supreme Court’s recent consideration of Moore v. United States has sparked a broad and deep academic interest in the…
This week, Adam Kern (San Diego; Google Scholar) reviews Daniel Hemel (NYU; Google Scholar), Formalism, Functionalism, and Nonfunctionalism in the Constitutional Law of Tax, 2025 Sup. Ct. Rev. __ : No Supreme Court case in recent memory has seized the attention of tax scholars quite like Moore v. United States. The Moores sought an answer…
This week, Doron Narotzki (Akron; Google Scholar) reviews a new paper by Mirit Eyal (Alabama; Google Scholar) and Yonathan A. Arbel (Alabama; Google Scholar), Tax Levers For A Safer AI Future: At a time of rapid and transformative revolutions, academia serves a crucial role: to identify emerging shifts, highlight their implications, and provide the critical…
This week, Young Ran (Christine) Kim (Cardozo; Google Scholar) reviews a recent article by Leopoldo Parada (King's College London; Google Scholar), U.N. International Tax Cooperation: The Terms of References Final Draft, 116 Tax Notes Int'l 771 (Nov. 4, 2024). The 30th session of the UN Tax Committee will take place next week from March 24…
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews a new work by Assaf Harpaz (Georgia; Google Scholar), Global Tax Wars in the Digital Era, 75 Am. U. L. Rev. __ (2025). Global tax has long been a tag-a-war in the international policy battleground for competing economic interests, but the rise of digitalization has intensified these tensions. The…
This week, David Elkins (Netanya, Google Scholar) reviews Daniel Hemel (NYU; Google Scholar), Law and the New Dynamic Public Finance, 43 Yale J. Reg. ___ (2026). In this week’s feature article, Professor Daniel Hemel takes us on a fascinating journey through the new dynamic public finance (NDPF), explaining its teachings and describing how they might be…
This week, Adam Kern (San Diego; Google Scholar) reviews Edward Fox (Michigan; Google Scholar) and Zachary Liscow (Yale; Google Scholar), The Role of Unrealized Gains and Borrowing in the Taxation of the Rich. Just before Mark Zuckerberg was born, William Andrews dubbed the realization rule the “Achilles heel” of the income tax. The main costs…
This week, Mirit Eyal-Cohen (Alabama; Google Scholar) reviews a new work by Ajay K. Mehrotra (Northwestern; Google Scholar), The Intellectual Origins of the Modern International Tax Regime: Edwin R. A. Seligman, Economic Allegiance, and the League of Nations’ 1923 Report, 5 J. L. & Political Econ. 995 (2025). As someone deeply fascinated by history and its nuanced…
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…
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…
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…
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…
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…
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…
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…
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.…
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…