Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Herzfeld: Clipping Treasury’s Rulemaking Wings
In Tax Notes, Mindy Herzfeld writes about two recent decisions from the Tax Court and the Court of Federal Claims in which the respective court each ruled against the government on the basis that Treasury exceeded its authority when it promulgated regulations implementing the 2017 tax overhaul informally known as the Tax Cuts and Jobs…
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AI Tokens and Sales Tax: Key Considerations
Stephen P. Kranz, Mark E. Nebergall & Jonathan C. Hague (McDermott Will & Schulte), AI Tokens and Sales Tax: Key Considerations, 121 Tax Notes State 239 (July 27, 2026): AI product providers increasingly offer customers access to their platforms through “tokens,” credits, or other usage-based entitlements. These arrangements may allow a customer to submit prompts, process…
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Second Circuit Rejects Counties’ Suit Against NYC Congestion Toll
This Second Circuit decision is important both for how it navigated the Tax Injunction Act and for its “right to travel” analysis. Cameron Browne (Tax Analysts): Second Circuit Rejects Counties’ Suit Against NYC Congestion Toll Two New York counties failed to prove that New York City’s congestion pricing program was an unauthorized tax that violated…
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AI Won’t Shrink Corporate Tax Teams Much. Here’s Why.
Michael V. Sala, AI Won’t Shrink Corporate Tax Teams Much. Here’s Why., 121 Tax Notes State 189 (July 20, 2026) In this article, Sala argues that the anticipated effects of artificial intelligence agents in modern corporate tax functions are greatly overstated because AI ultimately cannot shoulder regulatory, ethical, or financial consequences of culpability.
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Herzfeld: Mocking Up the Digital Services Tax War Games
Mindy Herzfeld (Florida), Mocking Up the Digital Services Tax War Games, 192 Tax Notes Fed. 185 (July 13, 2026) In the warning, which was issued the day after the European Commission agreed to the terms of the EU-U.S. trade deal, he threatened to impose a 100 percent tariff on all goods from countries that implemented a…
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Joint Center For Political And Economic Studies: Future of Black Communities Summit
Joint Center For Political And Economic Studies: Future of Black Communities Summit on July 16, 2026:
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House Ways and Means Exploring Perceived Disparity in Sports Team Pay Deduction
Cady Stanton (Tax Analysts): W&M Exploring Perceived Disparity in Sports Team Pay Deduction The top House taxwriter said his committee is considering whether expanding an upcoming cap on top earner salary deductions to all sports teams — not just those owned by publicly traded companies — could serve as a solution for concerns about unfair…
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More on NYC’s Pied-à-Terre Tax
Timothy P. Noonan, Lauren E. Austin & Noah S. Chase (Hodgson Russ LLP), Second Home, New Tax: Navigating NYC’s Pied-à-Terre Surcharge, 121 Tax Notes State 79 (July 13, 2026) It’s the first tax of its kind in New York state, and it’s finally here after more than a decade of failed proposals. Here, we walk through…
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Ryan: The Strengthen Social Security by Taxing Dynastic Wealth Act: Throwback or ‘Fauxback’?
Kerry A. Ryan (St. Louis University School of Law), The Strengthen Social Security by Taxing Dynastic Wealth Act: Throwback or ‘Fauxback’? (Tax Notes, July 9, 20026, 2026 TNTF 130-10) Throwback jerseys in professional sports are having a moment. “Throwbacks” are sports uniforms designed to resemble attire worn by a team in the past. Throwback uniforms have…
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Kalshi Sues Illinois to Nullify New Prediction Market Tax Law
Emily Hollingsworth (Tax Analysts): Kalshi Sues Illinois to Nullify New Prediction Market Tax Law Kalshi has filed suit in federal court to prevent Illinois from enforcing its new prediction market tax and licensing requirements, which the company says will cause it “irreparable harms.” The prediction market company filed its June 23 complaint under KalshiEX LLC v. Raoul in the U.S.…
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The New York Pied-à-Terre Tax: What You Should Know
David Pope & Chris Lorimer (DLA Piper): The New York Pied-à-Terre Tax: What You Should Know, 121 Tax Notes State 19 (July 6, 2026) In this article, Pope and Lorimer review the newly enacted New York City pied-à-terre tax, including its two-phase valuation structure, rate schedule, exemptions, potential constitutional issues, and the Department of Finance’s…
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Tax Notes: Check, Please: Workers React to ‘No Tax on Tips’ One Year In
Trevor Sikes & A.J. Collins, Check, Please: Workers React to ‘No Tax on Tips’ One Year In (Tax Analysts, 2026 TNTF 127-4) The qualified tips deduction, known as “No Tax on Tips,” has been touted by the Trump administration as a win for middle-income Americans, but some tipped workers told Tax Notes that the provision didn’t provide…
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Tax Notes: Soroban Gets Cool Reception on Limited Partner Argument
Kristen A. Parillo, in Tax Notes, provided an update on the oral argument in Soroban Capital Partners LP v. Commissioner, the Second Circuit case in which a taxpayer is challenging the government’s interpretation of the term “limited partner” in section 1402(a)(13): A panel of Second Circuit judges seemed highly skeptical of a New York hedge fund’s…
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Herzfeld: “SpaceX Speculation: Who Bears the Risk?”
Mindy Herzfeld (Florida), SpaceX Speculation: Who Bears the Risk?, 191 Tax Notes Fed. 2235 (June 29, 2026) But investors are presumably buying SpaceX shares on the expectation that the company will eventually become profitable. Assuming that happens, one question is how its business income might be taxed in the United States and elsewhere. Also of…
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Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case
David Schultz & Michael Rapoport (Bloomberg Law): Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case A panel of federal appellate judges were receptive to Coca-Cola Co.’s arguments that the IRS improperly allocated its foreign income in a case that could cost the soft drink company up to $20 billion.
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Clouse et al.: California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits
In Tax Notes, Jim Clouse, Fabio Natalucci, Charles W. Calomiris, Kenneth Rosen, David Bank, and Maxwell Hall, have written a new piece, “California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits.” From the introduction: The dire fiscal outlook for the state of California has prompted numerous proposals for ways to increase state…
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Florida Voters Will Decide Fate of Property Tax Relief Plan
Billy Hamilton (Tax Analysts): Florida Voters Will Decide Fate of Property Tax Relief Plan What makes this chain of events particularly interesting is that it combines three important trends in state and local tax policy and politics into a single issue. The first is the legislative desire, particularly in red states, to continue reducing taxes…
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Dale, Hemel & Manny: DAF Sponsors Should Stand Up for Nonprofit Sector Independence
Harvey Dale (NYU), Daniel Hemel (NYU), and Jill Manny (NYU), have a new piece in Tax Notes, DAF Sponsors Should Stand Up for Nonprofit Sector Independence, 191 Tax Notes Fed. 1305 (May 25, 2026). Here’s the abstract: The three largest sponsors of donor-advised funds jolted the philanthropic world in recent weeks when they announced that…
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Avi-Yonah: Taxation and Birthright Citizenship
Reuven Avi-Yonah (Michigan), “Taxation and Birthright Citizenship” (Tax Notes, June 8, 2026): Under the 14th Amendment, individuals who are born in the United States are U.S. citizens and citizens of the state where they reside if they are “subject to the jurisdiction” of the United States. The debate surrounding birthright citizenship focuses on the meaning…
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SALT Updates From the First Half of 2026
Billy Hamilton (Tax Notes): To Be Continued: Legislative Sessions End; Some Issues Don’t David Brunori (Law360): A Playground Of Unsound Tax Policy: SALT In Review Maria Koklanaris (Law360): State & Local Tax Takeaways From May
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Request For Nominations: Tax Analysts Award Of Distinction (State & Local Tax)
Tax Analysts is accepting nominations for its Award of Distinction in U.S. State and Local Taxation. Nominations are open now. The nomination form is here, and prior recipients are here. Additional details below the fold.
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Were Green Tax Credits Doomed From the Start?
Patrick Driessen, “Were Green Tax Credits Doomed From the Start?” (Tax Notes, June 1, 2026): When the energy consumption and business tax benefits (referred to here as green tax credits) were enacted in the Inflation Reduction Act (P.L. 117-169),1 the historical persistence of tax expenditures suggested that these provisions would survive almost any election cycle.…
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Crypto Asset Tax Legislation Progressing
Katie Lobosco (Tax Analysts): Bipartisan Crypto Tax Bill Introduced After Months of Discussion A bipartisan duo of House taxwriters introduced a bill that would address the way digital assets are taxed in an attempt to make it easier for consumers and investors to use digital payment technology. House Ways and Means Committee members Max L. Miller, R-Ohio,…
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Tax Notes: Shakira Shimmies Out of Spanish Tax Assessments for Fiscal 2011
William Hoke, Shakira Shimmies Out of Spanish Tax Assessments for Fiscal 2011 (Tax Notes Today, International, 2026 TNTI 96-9) Spain’s National High Court has annulled tax assessments issued to pop sensation Shakira for fiscal 2011 after finding that the singer was not a tax resident of the country during that year. In 2018 the Colombian-born singer,…
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Avi-Yonah: Liberty Global and the Revival of Economic Substance
In Tax Notes, Reuven Avi-Yonah (Michigan) has a new piece, “Liberty Global and the Revival of Economic Substance.” From the piece: This decision [Liberty Global, Inc. v. United States] is the third victory of the government in [economic substance doctrine (ESD)] cases, following Patel and Otay. But it is the most significant because it strikes…