Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Analysts
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More States Proposing Social Media Taxes and Digital Ad Taxes
As the tax world awaits a decision in the Maryland digital advertising tax cases, more state lawmakers are proposing their own iterations. Several states have focused on social media specifically, functioning as a per-user “data extraction” tax. While others mirror the Maryland approach but with refinements that may make the new tax regime less susceptible…
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Multistate Tax Commission Names New Executive Director
Bloomberg Law: “Keith Richardson, chief of the DC Office of Tax and Revenue, has been selected as the new executive director of the Multistate Tax Commission, an intergovernmental agency promoting tax uniformity and fairness across state tax systems.”
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Tax Notes: “Revived Digital Discussions? Just Don’t Call It Amount A”
Mindy Herzfeld (Florida), Revived Digital Discussions? Just Don’t Call It Amount A , 121 Tax Notes Int’l 1135 (Feb. 16, 2026): With multilateral agreement on an approach to pillar 2 that acknowledges that global intangible low-taxed income (now net controlled foreign corporation tested income) should be considered equivalent to the global minimum tax outlined by…
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White House Report Examines State Income Tax Elimination
Tax Notes: White House Report Examines State Income Tax Elimination A report from the White House touts the benefits of states eliminating their income taxes in favor of a broader sales tax, but one group contends that the report’s figures don’t hold up to scrutiny. The 18-page report from the White House’s Council of Economic Advisers, issued…
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Tax Notes: “Florida Man Wrestles an Alligator: Property Tax Edition”
Marie Sapirie (Tax Notes): Florida Man Wrestles an Alligator: Property Tax Edition Although this story won’t involve an alligator or a man kayaking down a public road attached to the tow hitch of a Ford F-150, it features things that only typically happen at scale in Florida — like lawmakers trying to eliminate property taxes…
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Avi-Yonah, Farrell & Imparato: Can the EU’s Foreign Subsidy Regulation ‘Discipline’ U.S. Subsidies?
Reuven S. Avi-Yonah (Michigan), Jennifer Farrell (Western University) & Domenico Imparato (Berkeley), Can the EU’s Foreign Subsidy Regulation ‘Discipline’ U.S. Subsidies?, 121 Tax Notes Int’l 837 (Feb. 2, 2026):
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ChatGPT Generates a Novel Tax Strategy
Artificial intelligence can now generate tax minimization strategies when fed only the text of tax authorities — without any internal IRS data and without any laborious hand coding of tax code sections.
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Request for Nominations: Tax Analysts U.S. Federal Tax Award of Distinction
Tax Analysts is accepting nominations for the 2026 Tax Analysts Award of Distinction in U.S. Federal Taxation. Nominations are open through January 30, 2026, and the nomination form is here. Criteria and more, below the fold.
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Tax Analysts Taxing Issues Series: Corporate Tax Incentives and CAMT After the OBBBA
Tax Analysts’s next episode of Taxing Issues, “Corporate Tax Incentives and CAMT After the OBBBA” will be on Wednesday, January 28, 2026, from 2-3 pm ET. You can sign up for this free webinar at the above link. As companies assess the favorable corporate tax changes introduced by the One Big Beautiful Bill Act, some…
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Tax Analysts: Federal and International Tax Developments to Watch in 2026
Mary Katherine Browne et al., Five Tax Cases to Watch in 2026, 190 Tax Notes Fed. 382 (Jan. 12, 2026): Litigation involving IRS regulation of microcaptive insurance, the validity of a related-party partnership’s basis adjustment claim, and the denial of a medical marijuana dispensary’s business deductions are among the tax cases to watch in 2026.
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State Tax Highlights of 2025: Tax Notes State Advisory Council
Tax Notes State: The Old and the New: In this inaugural installment of Briefly Noted, members of the Tax Notes State Advisory Council…share their state tax highlights of 2025.
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Tax Notes Podcast: 2026 U.S. Tax Legislation Forecast
Tax Notes Talk Podcast: 2026 U.S. Tax Legislation Forecast (Dec. 31, 2025) Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2025 developments in U.S. tax legislation and speculates what may lie ahead in 2026.
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New York Personal Income Tax Cases: A Year in Review
Timothy P. Noonan & Noah S. Chase, New York Personal Income Tax Cases: A Year in Review, 118 Tax Notes State 875 (Dec. 22, 2025): “2025 brought a bevy of interesting cases in New York of all tax types, including personal income tax, sales tax, and corporate tax…we’ll focus on a few of the more…
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Driessen: Senate OBBBA Deficit Denial Was Decades in the Making
Patrick Driessen, Senate OBBBA Deficit Denial Was Decades in the Making, 189 Tax Notes Federal 2013 (Dec. 22, 2025) The Senate used a current-policy baseline for the One Big Beautiful Bill Act (P.L. 119-21). That baseline suppressed $3.8 trillion each of revenue losses and deficit increases in the scoring of permanency for some temporary tax provisions first…
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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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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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Tax Analysts Launches New Award for Excellence in Federal Taxation
Tax Analysts is expanding its “Awards of Distinction” program with a new category for “excellence in U.S. federal taxation.” Nominations are now open for “leaders who make federal tax systems more effective, accountable, and transparent.” You can learn more and submit nominations here (the deadline in January 30, 2026).
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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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Li & Nikolakakis: Offshore Tax Havens
Jinyan Li (Osgoode) & Angelo Nikolakakis (EY Law LLP), Offshore Tax Havens: An Intriguing Problem for Canadian Tax Law, 2025 Tax Notes Today, Int’l 231-17 (Dec. 4, 2025) The use of offshore tax havens by Canadians and multinational enterprises is an intriguing problem for Canadian tax law. This submission explains why that is the case…
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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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Herzfeld: Rationalizing the Post-OBBBA International Tax Rules, Part 2
Mindy Herzfeld (Florida), Rationalizing the Post-OBBBA International Tax Rules, Part 2, 120 Tax Notes Int’l 1416 (Dec. 1, 2025) The second Trump administration’s regulatory priorities for Treasury are twofold: implementation of the One Big Beautiful Bill Act (P.L. 119-21) and deregulation. The 2025-2026 priority guidance plan issued on September 30 — significantly pared down from prior years’ plans — highlights the shift…
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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.
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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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Gamage & Shanske, NCTI is the New GILTI, and States Should Still Conform
David Gamage & Darien Shanski, NCTI is the New GILTI, and States Should Still Conform, 117:12 Tax Notes State 799 (Sept 22, 2025) This essay continues our series on corporate profit shifting by analyzing how states should respond to the federal One Big Beautiful Bill Act, which transformed GILTI into the new Net Controlled Foreign…