Author: Andrew D. Appleby
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OECD: Tokenized Assets Can Fall Outside Crypto Reporting
Bloomberg: Tokenized Assets Can Fall Outside Crypto Reporting, OECD Says “Tokenized instruments held the possibility of falling under both CARF and the common reporting standard, or CRS, the long-standing reporting regime for traditional financial institutions. The new guidance clarifies that these instruments will instead fall under CRS, eliminating the risk of dual reporting.”
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Trump Order Renews Hope for Cannabis Tax Relief
Tax Analysts: “President Trump has signed an executive order intended to expedite the marijuana rescheduling effort, bringing cannabis businesses ever closer to being able to deduct their expenses.”
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Boston Calls for State Legislative Action as Property Tax Spike Looms
Tax Notes: “Boston homeowners appear set to face a 13 percent average property tax increase next year after the city’s residential tax relief home rule petition failed to advance in the Massachusetts Legislature.”
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University of Tennessee Seeks Faculty Director of Externships
The University of Tennessee Winston College of Law invites applications for the faculty position of Director of Externships. The position will commence no later than August 1, 2026.
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Meta Contests $16 Billion in Deficiencies in U.S. Tax Court
Tax Notes: “Facebook’s parent company, Meta Platforms Inc., is challenging $15.95 billion in deficiencies and penalties in the U.S. Tax Court, saying that the IRS’s periodic adjustments are barred by estoppel and contravene the arm’s-length standard.”
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Levi’s Heir in Congress Pushes End to Tax Loophole for Ultrarich
Bloomberg: One of the wealthiest House Democrats will propose a bill Thursday that would edit the tax code to make it harder for ultrarich Americans to avoid paying taxes.
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New York Law Professor Continues Remote Work Taxation Fight
Tax Analysts: Professor Ed Zelinsky “is continuing his challenge against New York’s taxation of income he earned while working remotely from Connecticut during the COVID-19 pandemic.”
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Chicago Payroll Tax Draws Opposition From City’s Business Heads
Bloomberg: “A group backed by financier Michael Sacks has started funding ads against Chicago’s plan to bring back a tax on large corporate payrolls, drawing the ire of Mayor Brandon Johnson.”
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Graduate Accounting Education After CPA Licensure Reform
Mark J. Cowan, Joshua J. Filzen & Troy A. Hyatt, 118 Tax Notes State 639 (Dec. 1, 2025): When we last wrote about the pipeline problem (in late 2023), it was having a real impact from public accounting to government to private industry. We mentioned that the causes of the pipeline problem are manifold, including…
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Does California Punish Economic Freedom?
William Hays Weissman, 118 Tax Notes State 613 (Dec. 1, 2025): examining Florida v. California, “which questions California’s tax approach of using a single sales factor combined with a special rule excluding certain sales”
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NIL Era Brings Threat of Tax Exemption Abuses
Bloomberg (Andrew Leahey): “A recent FOIAball investigation into UCLA’s football program offers more than a peek at college sports fundraising in the era of name, image, and likeness compensation—it may expose a test case in tax enforcement. Public records suggest that donors were routed through a 501(c)(3) charity to support NIL deals while claiming tax deductions.”
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Data Center Development to Impact Income Tax Bases
Jurisdictions (both internationally and subnationally within the United States) initially competed to attract data centers using tax incentives, but are discovering that rapid growth has overwhelmed power grids and infrastructure capacity. These same jurisdictions now face environmental concerns and energy supply constraints. Compounding these challenges, the One Big Beautiful Bill Act (OBBBA) permits immediate full…
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Multistate Tax Commission Seeks New Executive Director
Per Michael Bologna at Bloomberg, the Multistate Tax Commission is seeking a new Executive Director as Greg Matson will be moving to private practice after a decade at the helm of the MTC. Heidi Humphreys, chair of the MTC’s executive committee and executive director of the Colorado Department of Revenue, will oversee the search.
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States Grapple with OBBBA Conformity
States are grappling with whether and to what extent their state tax codes should conform to or decouple from the federal tax provisions of the One Big Beautiful Bill Act (OBBBA).
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NYU Law: LLM in Taxation Information Session Tomorrow
The NYU Graduate Tax Program is hosting a virtual information session tomorrow at 12:30pm ET. Those interested in attending this LLM in Taxation information session can register at this link.
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Parsons Presents “Taxing Social Data” Today at Boston College
Amanda Parsons (Colorado) presents Taxing Social Data at Boston College today at 5pm ET as part of its Tax Policy Collaborative hosted by James Repetti and Diane Ring:
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Nam Presents “Desert-Based Taxation” Today at Pepperdine
Jeesoo Nam (USC; Google Scholar) presents Desert-Based Taxation today at Pepperdine, as part of its Tax Policy Workshop Series:
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WSJ: “Trump’s Tax Cuts Are Exposing Companies to Biden’s Tax Hike”
Wall Street Journal: Trump’s Tax Cuts Are Exposing Companies to Biden’s Tax Hike: Democrats’ older alternative minimum tax claws back billions of dollars in savings from newer GOP law.
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Avi-Yonah, Salama, Snitz & Thomas: Boden Lecture: Taxation of Autonomous Artificial Intelligence
Reuven Avi-Yonah (Michigan; Google Scholar), Lucas Brasil Salama, Herbert Snitz, and W. Robert Thomas, Boden Lecture: Taxation of Autonomous Artificial Intelligence, 108 Marq. L. Rev. 1081 (2025). This Article proposes that tax can be a useful supplement to other measures to regulate Autonomous Artificial Intelligence (AAI) and limit its potential harmful effects.
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Penn Wharton Budget Model: OBBBA International Tax Reforms
Penn Wharton released updated cost estimates for the OBBBA International Tax Reforms: Summary: We project that corporate tax revenue will decrease by $276 billion over 10 years on a conventional basis due to changes in international tax provisions related to the Section 250 deduction under OBBBA.
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Florida Sues California in U.S. Supreme Court Over “Special” Apportionment Rule
Tax Notes State, Florida Sues California Over ‘Special’ Apportionment Rule: Florida is challenging a California rule for apportioning business income, arguing that it violates the U.S. Constitution.
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WSJ: “How to Squeeze the Most From the New SALT Cap”
Wall Street Journal, How to Squeeze the Most From the New SALT Cap: President Trump’s “big, beautiful bill” bumped the limit on state and local tax deductions, known as the SALT cap, to $40,000 from $10,000. Whether you’re married or single, the new cap is $40,000 and starts phasing down once income reaches $500,000, so strategies for…
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Infanti presents “The Human Toll: Taxation and Slavery in Colonial America” today at Pepperdine
Anthony Infanti (Pittsburgh) presents his book, The Human Toll: Taxation and Slavery in Colonial America, today at Pepperdine, as part of its Tax Policy Workshop Series: How the thirteen colonies deployed the power of taxation to support, promote, and perpetuate the institution of slavery
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Bearer-Friend: Three New AI Articles
Jeremy Bearer-Friend (GW) posted three new AI articles on SSRN:
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Harpaz Presents “Taxing AI” at Mizzou Law Tax Policy Colloquium
Assaf Harpaz (Georgia) presented Taxing AI at the Mizzou Law Tax Policy Colloquium on October 22: Artificial intelligence (AI) is changing the world and is introducing numerous challenges to legal and regulatory frameworks. These tensions are highlighted in federal income taxation, which broadly serves three principal goals: revenue generation, redistribution, and regulation of taxpayer behavior.…