Author: Jon Endean
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WHCEA: The Economic Impact of State Income Tax Elimination
The White House Council of Economic Advisers has published a new report titled, The Economic Impact of State Income Tax Elimination. From the report’s executive summary: For years, no-income-tax states like Texas, Tennessee, and Florida have often led the pack in attracting and retaining residents looking to put down roots where they do not have
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Fleischer: A New Look at Old Money
Miranda Perry Fleischer (San Diego), has published a new piece, A New Look at Old Money, 98 S. Cal. L. Rev. 1439 (2025) (reviewed by David Elkins here):
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released two new reports concerning (1) various issues arising under section 704(c)(1)(A) and (2) IRS Notice 2025-72, which addressed the repeal of section 898(c), The Report provides comments and certain recommendations of the Tax Section regarding section 704(c)(1)(A) of the Internal Revenue Code, which governs
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Reflections on the Fifth Circuit’s Ruling on Limited Partner Exception
On Friday, the Fifth Circuit, in a 2–1 decision in Sirius Solutions, LLLP v. Commissioner, held that the term “limited partner” in section 1402(a)(13) is “a partner in a limited partnership that has limited liability,” reversing the Tax Court’s rule that a limited partner refers only to passive investors in a partnership. This post will summarize
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Galle et al.: Expert Report on Valuation of Controlling Shares of Publicly Traded Companies Under the California Billionaire Tax Act
Brian Galle (UC Berkeley), David Gamage (University of Missouri), Emmanuel Saez (UC Berkeley), and Darien Shanske (UC Davis) have produced a memo attempting to address concerns over the proposed California Billionaire Tax Act:
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NYT: Newsom Vows to Stop Proposed Billionaire Tax in California
Laurel Rosenhall, Newsom Vows to Stop Proposed Billionaire Tax in California, N.Y. Times (Jan. 13, 2026): Gov. Gavin Newsom vowed on Monday to stop a proposed wealth tax in California, saying that its mere introduction had already hurt the state by driving some billionaires to relocate and take their tax dollars with them. Mr. Newsom,
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Borden: A Critical Analysis of Alternative Section 1031 Proximate-Exchange Structures
Brad Borden (Brooklyn) has published a new piece, A Critical Analysis of Alternative Section 1031 Proximate-Exchange Structures, 22 UC Law SF Bus. L. J. 81 (2025):
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Cahill: Home Sweet Home Deduction
Collin Cahill (J.D. 2025, Ohio State), Home Sweet Home Deduction, 25 U.C. Davis Bus. L.J. 29 (2025):
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Loayza Jordán presents “International Tax Peace” at JILSA Annual Meeting
Fernando Loayza Jordán (Drexel-Kline, Yale) presented “International Tax Peace” on January 6 at the Junior International Law Scholars Association annual meeting at the University of Hawai’i in Honolulu. Here is the abstract:
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Elkins: Embracing Tax Avoidance
David Elkins (Netanya), Embracing Tax Avoidance, 34 U. Fla. J.L. & Pub. Pol’y 327 (2024):
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Swigart: A New Age of Equity: Machine Learning and Equity in Tax Law
Nathaniel Swigart (J.D. 2025, North Carolina), Note, A New Age of Equity: Machine Learning and Equity in Tax Law, 29 Tex. Rev. L. & Pol. 145 (2024):
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Narotzki & Shanan: Taxing Morality: How Tax Law Defines Wealth, Justice, and Fairness
Doron Narotzki (Akron) & Tamir Shanan (Haim Striks Faculty of Law, College of Management, Israel), Taxing Morality: How Tax Law Defines Wealth, Justice, and Fairness, 41 Ga. St. U. L. Rev. 943 (2025):
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Romney (NYT): Tax the Rich, Like Me
Mitt Romney, Opinion, “Tax the Rich, Like Me,” N.Y. Times (Dec. 19, 2025): Typically, Democrats insist on higher taxes, and Republicans insist on lower spending. But given the magnitude of our national debt as well as the proximity of the cliff, both are necessary.
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SCOTUSBlog: How the Tariffs Could Be Refunded if the Court Sides Against Trump
Amy Howe, “How the Tariffs Could Be Refunded if the Court Sides Against Trump,” SCOTUSBlog (Dec. 18, 2025): It has been slightly over six weeks since the Supreme Court heard oral arguments in the challenge to President Donald Trump’s power to impose sweeping tariffs in a series of executive orders earlier this year. During the
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NYT: “Big Businesses Are Cashing In on Trump’s Tax Cuts”
Andrew Duehren, Big Businesses Are Cashing In on Trump’s Tax Cuts, N.Y. Times (Dec. 12, 2025): In the months since the passage [of the 2025 budget bill] in July, corporations like Walmart, Amazon, Verizon and Eli Lilly have all disclosed in securities filings that the law would reduce their cash tax payments in the near
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Politico: “Trump Administration Races to Finalize Tariff Payments — and Hamstring Possible Refunds”
Ari Hawkins & Doug Palmer, Trump Administration Races to Finalize Tariff Payments — and Hamstring Possible Refunds, Politico (Dec. 14, 2025): The Trump administration is racing to deposit the money it’s raised from tariffs into the U.S. Treasury, a tactic that could make it harder for companies to get refunds for duties the Supreme Court
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released three new reports concerning (1) the “signing date rule” found in the Treasury Regulations describing the continuity of interest requirement for tax-free reorganizations under section 368, (2) the impact of section 68 and its cap on the availability of itemized deductions for taxpayers in
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McCormack: “America’s Failure to Rescue Parents: A Narrative of Inequitable Tax ‘Reform’”
Shannon Weeks McCormack (University of Washington), America’s Failure to Rescue Parents: A Narrative of Inequitable Tax “Reform,” 76 U.C. L.J. 751 (2025):
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Florida Tax Review Publishes New Issue
The Florida Tax Review has published a new issue of volume 28. The articles are a part of its symposium issue, titled Moore, Loper Bright, Corner Post, and the Future of the Federal Tax System. Here are the articles in that issue:
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Colinvaux: “Charitable Giving and Civil Rights: A Defense of Private Remedial Action”
Roger Colinvaux (Catholic University), Charitable Giving and Civil Rights: A Defense of Private Remedial Action, 135 Yale L.J. 549 (2025):
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NY Times: Ahead of Tariff Ruling, Businesses Race to Secure Refunds
Tony Romm & Ana Swanson, Ahead of Tariff Ruling, Businesses Race to Secure Refunds, N.Y. Times (Dec. 3, 2025): From the buy-in-bulk retailer Costco to the canned-tuna company Bumble Bee Foods, some businesses are racing to get in line for tariff refunds, anticipating that the Supreme Court will soon rule against President Trump and force
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Wei & Zhou: “Captain Gains” on Capitol Hill (NBER)
Shang-Jin Wei (Columbia Business School) & Yifan Zhou (Xi’an Jiaotong-Liverpool University) have a new National Bureau of Economics Research working paper, “‘Captain Gains’ on Capitol Hill.” Here is the abstract:
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Florida Levin College of Law Seeking to Hire Tax VAP
University of Florida Levin College of Law is seeking to hire one or two visiting assistant professors in tax to begin in the fall of 2026. VAPs will spend one or two years in residence at the Levin College of Law and will teach one class per semester in the JD tax or LLM tax
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Narotzki: Predicting Tariff Decisions from Oral Argument Transcripts with AI Models
Doron Narotzki (Akron) has a new working paper on SSRN, Predicting Tariff Decisions from Oral Argument Transcripts with AI Models. Here is the abstract:
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Hellerstein & Appleby: A State Tax Perspective on Proposed Federal Cryptoasset Guidance
Walter Hellerstein (Georgia) & Andrew Appleby (Tennessee), A State Tax Perspective on Proposed Federal Cryptoasset Guidance, 189 Tax Notes Fed. 1285 (Nov. 24, 2025). In this article, Hellerstein and Appleby consider the state tax implications of proposed federal income tax guidance on the treatment of cryptoassets.