Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Blaine Saito
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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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TaxProf Op-Ed: Saito on Major Questions, Learning Resources, and the End of Tax Regulation
This TaxProf Op-Ed on Learning Resources is by Blaine Saito (Ohio State; Google Scholar): Major Questions, Learning Resources, and the End of Tax Regulation Blaine Saito The Supreme Court’s decision in Learning Resources, Inc. v. United States[1] did more than just strike down a set of emergency tariffs. It effectively doubled down on the Major Questions Doctrine (MQD) without helping
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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: 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