Author: Andrew D. Appleby
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Utah Takes Montana License Plate Fight to 80,000 Vehicle Owners
Michael Bologna (Bloomberg Law): Utah Takes Montana License Plate Fight to 80,000 Vehicle Owners At least 10 states — including Illinois, Maryland, and Minnesota — have adopted laws or enforcement initiatives in the past year targeting residents who register their cars, trucks, boats, and aircraft through Montana limited liability companies. California has leveled criminal tax…
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Shanske: Md. Court Got Ad Tax Similarity Analysis Wrong
Darien Shanske (UC Davis): Md. Court Got Ad Tax Similarity Analysis Wrong, Law360 (Sept. 9, 2026) The decisions in Peacock TV LLC v. Comptroller of Maryland, Apple Inc. v. Comptroller of Maryland and Google LLC v. Comptroller of Maryland struck down the statute on numerous grounds from preemption to discrimination. This essay addresses the court’s…
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Kern Presents “Separation of Bases and the Fiscal Constitution” Today at Northwestern
Adam Kern (San Diego) presents Separation of Bases and the Fiscal Constitution at Northwestern today as part of its Advanced Topics in Taxation Colloquium hosted by Ari Glogower: A central concern of constitutional law and theory is the question of tax assignment: In a multilevel system of government, who gets to tax what? One conventional…
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Gordon Presents “Tax and the Law of Market Cycles” Today at Missouri
Jeff Gordon (Vanderbilt) will present Tax and the Law of Market Cycles at Missouri today as part of its Tax Policy Colloquium hosted by David Gamage, from 2:00 to 3:15 pm (CDT). The session will be open to guest participants via Zoom. Anyone who would like to join as a guest participant should email Professor…
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Herzfeld: “Will the Bond Market Force Congress’s Tax Hand?”
Mindy Herzfeld (Florida): Will the Bond Market Force Congress’s Tax Hand?, 192 Tax Notes Fed. 1749 (Sept. 7, 2026) Warnings about the dangers of an ever-increasing federal deficit have persisted for years, but Congress, successive administrations, the economy, and the markets shrugged them off. However, the latest sign of unease comes from a corner that…
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SALT Break Sought by New York, California Pays Off Across the US
Caitlin Reilly (Bloomberg Law): SALT Break Sought by New York, California Pays Off Across the US The expanded state and local tax deduction championed by New York lawmakers is gaining favor around the US, benefiting well-heeled taxpayers in states like Ohio, Colorado, North Carolina, Michigan and Pennsylvania. … Some counties in Florida and states in…
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Polsky & Yale: “Fixing the QSBS Stacking Problem”
Gregg D. Polsky (NYU) & Ethan Yale (UVA): Fixing the QSBS Stacking Problem, 192 Tax Notes Fed. 1769 (Sept. 7, 2026) As nearly every sentient U.S. tax adviser knows by now, section 1202, which shelters certain gains from the sale of qualified small business stock (QSBS) from tax, is manna from heaven for the venture capital…
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California Fix for Montana Plates Tax Loophole Heads to Newsom
Brad Hooker (Bloomberg Law): California Fix for Montana Plates Tax Loophole Heads to Newsom California lawmakers are moving to shut down a tax maneuver that luxury vehicle owners use to avoid paying state taxes. The Assembly Wednesday approved a bill (SB 1406) by Sen. Jerry McNerney (D) to close what’s known as the “Montana loophole,” where…
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Alternative Apportionment: 2026 Flashpoints
Amy Hamilton (Tax Analysts): Alternative Apportionment: 2026 Flashpoints
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WSJ: ‘A Roth IRA on Steroids’: Wealthy Americans Find Another Tax-Free Way to Invest
Miriam Gottfried (WSJ): ‘A Roth IRA on Steroids’: Wealthy Americans Find Another Tax-Free Way to Invest Enter private-placement life insurance, a customizable insurance contract that allows unlimited investments to grow tax-free. “It is a Roth IRA on steroids for people who can afford it and want to leave it to their heirs,” said Jim White, founder…
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Maryland Digital Ad Tax Rulings Shift Debate to What Comes Next
DeAndre Morrow (Greenberg Traurig): Maryland Digital Ad Tax Rulings Shift Debate to What Comes Next, Bloomberg Tax (Aug. 21, 2026): Although the decisions may be viewed as taxpayer victories, they aren’t the final word and instead shift the controversy into its next phase. The comptroller has indicated that Maryland will continue defending the tax and intends…
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More on Tax-Aware Long-Short Investing Strategies
Loukia Gyftopoulou, Paige Smith & Charlie Wells (Bloomberg): The Ultrawealthy Tax Maneuver That’s Spooking Schwab and Fidelity For months, the brokerage had piled into one of the hottest trades on Wall Street: “tax-aware long-short” accounts, which are helping legions of wealthy investors whittle down their tax bills. Millionaires love it so much they’ve poured roughly…
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“Taylor Swift Tax” Draws Suit From Rhode Island Homeowners
Peyton Rhodes (Bloomberg Law): ‘Taylor Swift Tax’ Draws Suit From Rhode Island Homeowners Rhode Island’s new tax on second homes disproportionately targets non-residents and has no reasonable basis for its selective application, according to a new suit challenging the tax on federal and state constitutional grounds. Dubbed the “Taylor Swift Tax” after the state’s famous…
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Oren-Kolbinger Presents “Timing Matters: Sequencing AI in Tax Education” Today at Pepperdine
Orli Oren-Kolbinger (Oregon) presents Timing Matters: Sequencing AI in Tax Education, 24 Pitt. Tax Rev. ___ (2026) (AI and Teaching Taxation), today at Pepperdine as part of its Tax Policy Workshop Series hosted by Deanna Newton: Artificial intelligence (AI) now plays a growing role in legal education. Instructors use AI technology to develop classroom exercises, discussion questions, simulations, visual organizers,…
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Law Professor Appeals Remote Taxation Case to New York High Court
Cameron Browne (Tax Analysts): Law Professor Appeals Remote Taxation Case to New York High Court Zelinsky, a professor at the Benjamin N. Cardozo School of Law in New York City, filed a motion on July 20 to appeal the New York Supreme Court, Appellate Division’s July 2 decision in Zelinsky v. New York Commissioner of Taxation and Finance. In an…
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Trump Says US Weighing Attempt to Stop NYC Pied-A-Terre Tax
Hadriana Lowenkron (Bloomberg Law): Trump Says US Weighing Attempt to Stop NYC Pied-A-Terre Tax President Donald Trump said he would examine whether the federal government can stop New York City Mayor Zohran Mamdani’s new pied-à-terre tax, which was temporarily blocked by a state court. Trump in a social media post on Tuesday argued that the policy…
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Setting the Standard: A Major Development in Connecticut Domicile Cases
Timothy P. Noonan & Noah S. Chase (Hodgson Russ LLP), Setting the Standard: A Major Development in Connecticut Domicile Cases, 121 Tax Notes State 531 (Aug. 17, 2026) Over the years, we’ve spent a lot of time exploring the nuances of state tax residency and domicile issues in New York and other states. This is…
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Maryland Tax Court Invalidates Digital Ad Tax on Constitutional and ITFA Grounds
In what is possibly the most important state tax decision in the past two decades (aside from Wayfair), the Maryland Tax Court struck down Maryland’s digital advertising tax on Friday. The court held that the tax violated the Commerce Clause and Due Process Clause of the U.S. Constitution, and was also preempted by the federal…
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Pied-à-Terre Owners Sue NYC, Seek to Avoid Tax
Chris Dolmetsch (Bloomberg Law): Mamdani Handling of Pied-à-Terre Tax Contested by Homeowners New York City was sued by a group of homeowners seeking to delay the rollout of Mayor Zohran Mamdani’s new pied-à-terre tax, saying the publication of a list of properties that could be subject to the levy has caused “mass confusion” and invited “unwarranted…
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Trump’s Latest Tariffs Hit With New Lawsuit by 25 States
Erik Larson (Bloomberg Law): Trump’s Latest Tariffs Hit With New Lawsuit by 25 States A group of 25 states filed a lawsuit challenging President Donald Trump’s new global tariffs that went into effect last month, adding to similar complaints by small businesses who claim the levies are illegal. New York, California, Illinois and other states…
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The Supreme Court’s 2025 Term in Tax
Jasper L. Cummings, Jr. (Alston & Bird), The Supreme Court’s 2025 Term in Tax, 192 Tax Notes Fed. 867 (Aug. 3, 2026): This is my 15th annual review of Supreme Court opinions relevant to state and federal taxation. As usual, other conflicts crowded out the tax cases except for the one big one addressing tariffs, which was of…
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(Even) More on NYC’s Pied-à-Terre Tax
It was an eventful week for the NYC Pied-à-Terre Tax. It started with the City publicly identifying 31,000 properties (and their owners) that might be subject to the tax—more than triple the initial estimate of taxable properties. What followed was substantial backlash, including particular criticism regarding the City’s truncated exemption application timeline. Although Mayor Mamdani…
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Utah’s Targeted Ad Tax Draws First Challenge from Advocacy Group
Peyton Rhodes (Bloomberg Law): Utah’s Targeted Ad Tax Draws First Challenge from Advocacy Group The Utah Taxpayers Association is taking aim at the 4.7% levy on targeted advertising entities’ gross receipts signed into law in March. The federal Internet Tax Freedom Act and the US Constitution’s Commerce Clause and Due Process Clause preempt the state’s tax, according…
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MTC Expands Digital Tax Project to Prediction Markets, Crypto
Michael Bologna (Bloomberg Law): States Expand Digital Tax Project to Prediction Markets, Crypto The Multistate Tax Commission expanded the scope of its digital products work group on Tuesday to include several “alternative taxes” enacted in such states as Illinois, Maryland, and Washington over the past year that impose levies on new features of the digital economy.
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Cryptocurrency Trade Group Sues Illinois Over Digital Asset Tax
Michael J. Bologna (Bloomberg Law): Cryptocurrency Trade Group Sues Illinois Over Digital Asset Tax A major cryptocurrency trade group is asking an Illinois court to block the nation’s first state tax on digital asset transactions, describing it as discriminatory, unconstitutional, and prohibited under federal law. The Digital Chamber filed a lawsuit Tuesday against the Illinois Department of…