Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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Tax Notes State Council: Spring Installment of “Briefly Noted”
In this spring installment of Briefly Noted, members of the Tax Notes State Council speculate on the next areas for state compliance activity.
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Details of New IRS Conservation Easement Settlement Offer
Kristen Parillo (Tax Analysts): New IRS Easement Settlement Offer Eliminates Up-Front Payment Eligible partnerships that accept the terms of the IRS’s latest — and purportedly final — settlement offer for syndicated conservation easement and historic preservation easement cases won’t be required to pay the full settlement amount up front. The liability will instead be subject to…
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Viswanathan: Toward Issuer-Based Certification of Qualified Small Business Stock
Manoj Viswanathan (UC Law SF), Toward Issuer-Based Certification of Qualified Small Business Stock, 191 Tax Notes Fed. 369 (Apr. 20, 2026): The qualified small business stock (QSBS) exclusion under section 1202 allows shareholders of certain startups to exclude from income tax the greater of $10 million ($15 million for stock acquired after July 4, 2025) or 10…
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California Decisions Raise Remote Contractor Income Sourcing Questions
Two recent California decisions highlight the difficulty of sourcing remote independent contractor income. California regulations provide that if a nonresident individual’s business, trade, or profession is carried on entirely outside California, then no portion of the net income is derived from sources within the state. But if a nonresident’s business, trade, or profession is a…
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Beyond Homeowner Preference: Three Frames for Housing Taxation
Yijie Chen (J.D. 2027, Indiana-Maurer) & Stephanie Hunter McMahon (Indiana-Maurer), Beyond Homeowner Preference: Three Frames for Housing Taxation, 191 Tax Notes Fed. 95 (Apr. 13, 2026): Much of the existing discussion of housing’s tax advantages tends to emphasize a familiar subset of homeowner-facing provisions, which can make the system look like a simple story of…
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Checking In on Data Taxes and Related Reforms
Peter D. Enrich, Michael Mazerov, Darien Shanske, Robert D. Plattner & Doug Sheppard, Checking In on Data Taxes and Related Reforms, 120 Tax Notes State 333 (May 4, 2026). In this installment, the authors evaluate the latest state proposals to tax data and digital services, as well as the chances of recently enacted data tax…
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New York City Leaders Call for Reduced Passthrough Entity Credit
Emily Hollingsworth (Tax Notes): New York City Leaders Call for Reduced Passthrough Entity Credit Mayor Zohran Mamdani (D) and City Council Speaker Julie Menin (D) on April 28 jointly announced their support of a proposal to reduce the city PTE tax credit from 100 percent to 75 percent. … “A reduction would ensure the wealthiest pay their…
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Some Actual Facts on California’s Billionaire Tax
Brian Galle, David Gamage, Emmanuel Saez & Darien Shanske, Letter to the Editor: Some Actual Facts on California’s Billionaire Tax There has been a string of critiques published in Tax Notes State as to the California billionaire tax proposal…In the end, our point is not to argue here for the billionaire tax at length. Our point, rather,…
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Tax Analysts Public Service Fellowship Application Now Open
The ABA Tax Section partnered with Tax Analysts to launch the Tax Analysts Public Service Fellowship program in 2022. This fellowship funds attorneys with experience practicing tax law to work for two years providing public service tax legal assistance in areas where there is a current gap in services. The application period for the 2026-2028…
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Camp: The New Forever Rule for Tax Record Retention
Bryan T. Camp (Texas Tech), The New Forever Rule for Record Retention, 190 Tax Notes Fed. 2183 (Mar. 30, 2026): W]hen people ask me how long they must keep their tax records, they are in effect asking how long they will run the risk of audit. My traditional answer had been three years. That is…
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Thorndike: Who Gets the Tariff Refund? A Lesson From 1936
Joseph J. Thorndike, Who Gets the Tariff Refund? A Lesson From 1936, 191 Tax Notes Federal 175 (Apr. 13, 2026): Shortly after the Supreme Court invalidated many of President Trump’s cherished tariffs, Illinois Gov. JB Pritzker (D) sent the White House a bill. “On behalf of the people of Illinois, I demand a refund of $1,700 for every…
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Prediction Market Tax Proposals Gain Momentum in State Houses
Michael Bologna (Bloomberg Law): Prediction Market Tax Proposals Gain Momentum in State Houses Initiatives to regulate and tax prediction markets are accelerating in the closing weeks of state legislative sessions, with many lawmakers denouncing the fast-growing trading platforms as a form of unlicensed and unregulated gambling. State lawmakers contend the markets resemble sports wagering that…
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Goulder: Can Consumers Recoup IEEPA Tariffs From Importers?
Robert Goulder, Can Consumers Recoup IEEPA Tariffs From Importers? (Tax Notes Today, Int’l, April 10, 2026) The one-year anniversary of President Trump’s “Liberation Day” tariffs came and went without much public fanfare. The kindest remembrance was penned by columnist Oren Crass for the Financial Times, who credits Trump’s trade stance for a weaker (read: more competitive)…
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Joondeph: Florida v. California and the Fair Apportionment of Corporate Income
Bradley W. Joondeph (Santa Clara, SSRN), Florida v. California and the Fair Apportionment of Corporate Income, 120 Tax Notes State 7 (Mar. 31, 2026): The Supreme Court is unlikely to grant Florida leave to file its complaint, in large part because Florida appears to lack standing to assert its claims in federal court. (It is unclear…
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Eyal & Soled: Eliminate the Gambling Loss Tax Deduction
Mirit Eyal (Alabama) & Jay A. Soled Rutgers, Eliminate the Gambling Loss Tax Deduction, 190 Tax Notes Fed. 2029 (Mar. 23, 2026): To some, gambling is an exciting and joyful activity — an opportunity to beat the odds and prove one’s savviness or luck. To others, gambling is nothing less than a pure vice that,…
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Trencs: The End of the Penny: Navigating Rounding Rules and Audit Risks
Samantha K. Trencs, The End of the Penny: Navigating Rounding Rules and Audit Risks (Tax Notes, April 3, 2026) Your total is $10.02 at a retail checkout, but as you reach into your pocket, the cashier stops you: There is no need for those 2 cents. This scenario, once the subject of debate and hypothetical…
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State QSBS Conformity
State conformity to the federal tax code is a messy and constantly evolving process. The conformity stakes are raised exponentially when Congress enacts substantial tax preferences, as it did in 2017 with the TCJA and again last year with the OBBBA. Despite the Treasury Secretary’s reproach, almost all states will decouple from certain federal tax…
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Washington State’s Odd Place in the Millionaire’s Tax Debate
Billy Hamilton (Tax Notes): Washington State’s Odd Place in the Millionaire’s Tax Debate Flying in the face of this long history of failure, the Democrat-controlled Legislature is taking another swing at the elusive income tax this year, but they’re proposing not a general income tax, but one that targets the state’s richest taxpayers: a millionaire’s…
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Alvin Warren’s Tax Oeuvre
Jasper L. Cummings, Jr. (Alston & Bird, Raleigh, NC), Alvin Warren’s Writings, 190 Tax Notes 1469 (Mar. 3, 2026): Practitioners routinely ignore, or are not exposed to, so-called academic articles on tax. Usually it doesn’t matter because academic articles are seldom useful in practice. Occasionally, an appellate brief making a constitutional argument will cite one. But…
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Herzfeld: Wars and Oil Crises Drive Tax Policy Shifts
Mindy Herzfeld (Florida), Wars and Oil Crises Drive Tax Policy Shifts, 121 Tax Notes Int’l 2101 (March 23, 2026) The U.S. bombing of Iran has disrupted oil shipments through the Strait of Hormuz, leading to wild swings in the price of oil and reports of windfall profits for U.S. oil companies. (See “U.S. Oil Groups…
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Thorndike: The Misguided Drive to Hollow Out the Income Tax
Joseph Thorndike, “Everybody’s Tax: The Misguided Drive to Hollow Out the Income Tax” (Tax Notes, March 17, 2026): Democrats are competing to exempt Americans from the income tax. Sen. Chris Van Hollen, D-Md., wants to eliminate federal income taxes for workers earning up to $46,000 individually or $92,000 for married couples filing jointly, according to news…
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Washington State Legislature Approves Millionaire’s Tax
Tax Notes: Washington Legislature Approves Millionaire’s Tax Washington lawmakers have approved a new income tax on millionaires, securing a key legislative victory for progressive tax reformers. S.B. 6346 is set to be signed by Gov. Bob Ferguson (D), likely setting the stage for a legal fight before the state supreme court and a potential ballot repeal effort by…
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MTC Fights Federal Intervention in Hawaii Cruise Ship Tax Case
Amy Hamilton (Tax Notes): MTC Fights Federal Intervention in Hawaii Cruise Ship Tax Case The Multistate Tax Commission is urging the Ninth Circuit to reject the U.S. Justice Department’s intervention in a Hawaii tax dispute as improper overreach that could let the federal government sidestep the Tax Injunction Act. In a February 25 amicus brief in Cruise Lines International Association Inc. v. Suganuma,…
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Avi-Yonah: “Should Single-Sales-Factor Formulas Be Constitutional?”
Reuven S. Avi-Yonah (Michigan; SSRN): Should Single-Sales-Factor Formulas Be Constitutional?, 119 Tax Notes State 683 (Mar. 2, 2026). On October 28, 2025, Florida sued California in the Supreme Court over its application of a single-sales-factor (SSF) formula to exclude large out-of-state asset sales. But Florida couched its critique in much broader terms, seemingly attacking the validity…
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NY Times: Why the I.R.S. Wants $15 Billion From Meta
From Jesse Drucker, Alexandra Ostasiewicz, June Kim, and Joey Sendaydiego, the New York Times produced a video explaining dispute between Meta (the holding company of Facebook) and the IRS that is currently pending in the Tax Court. At issue is a notice of deficiency from the IRS of just under $16 billion (before interest and…