Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Daily
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WSJ: Rivian Deliveries Decline Following Expiration of Tax EV Credit
Wall Street Journal, Rivian Deliveries Decline Following Expiration of Tax EV Credit: The company delivered 9,745 vehicles during the fourth quarter of 2025. Rivian’s production and delivery totals declined in its first quarter since the expiration of a key tax credit for electric vehicles. The EV maker on Friday said it produced 10,974 vehicles at…
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State and Local Tax Cases to Watch in 2026
Richard Tzul, Bloomberg Law: Three State and Local Tax Cases Practitioners Must Watch in 2026: Next year has the potential for landmark state and local tax decisions that affect the broader legal landscape in addition to the discrete tax issues they address. Pending cases in New York, South Carolina, and Maryland touch on apportionment, agency…
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Sports Betting Alliance sues Chicago over proposed licensing, tax
ESPN, Sports Betting Alliance sues Chicago over proposed licensing, tax: The Sports Betting Alliance, an advocacy group for several of the nation’s major sportsbooks, sued the city of Chicago on Tuesday, seeking to prevent it from enforcing a new ordinance that would levy a tax on its member sportsbooks within city limits. The ordinance, which…
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Federal ruling blocks Hawaii’s climate change tourist tax on cruise ships
ABC News, Federal ruling blocks Hawaii’s climate change tourist tax on cruise ships: HONOLULU — A federal appeals court ruling on New Year’s Eve blocked Hawaii from enforcing a climate change tourist tax on cruise ships passengers, a levy that was set to go into effect at the start of 2026. Cruise Lines International Association challenged the tax…
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Citadel Leaves Chicago Tower as City Faces ‘Job Killer’ Tax
Bloomberg Law: “Citadel is shrinking its footprint in Chicago three years after billionaire owner Ken Griffin left for Florida, moving the company’s remaining operations in the city out of the downtown tower that was named for it, according to people familiar with the matter.”
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Reuters: Tax Experts on OBBBA Changes to Opportunity Zones
Reuters: Tax Experts on OBBBA Changes to Opportunity Zones: Recent Baker Tilly year-end tax webinars highlighted sweeping changes to the Opportunity Zone program under the One Big Beautiful Bill Act, with experts urging practitioners and taxpayers to carefully navigate new rules, compliance demands, and state-federal conformity as tax season approaches. Background Opportunity Zones (OZs) were…
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Bloomberg: IRS Foreign-Derived Income Guidance Rewards US-Based Intangibles
Bloomberg, IRS Foreign-Derived Income Guidance Rewards US-Based Intangibles: Recent guidance released by the IRS on what kinds of foreign-earned income qualify for a highly lucrative tax deduction underscores Republicans’ goal of rewarding companies for keeping IP in the US, tax practitioners say. The guidance is “very consistent with the policy we’ve seen in OBBBA as…
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Bloomberg: AI Use Helps UK Tax Authority Recover About £8 Billion Annually
Bloomberg, AI Use Helps UK Tax Authority Recover About £8 Billion Annually: The use of AI by the UK tax office has resulted in the recovery of at least £8 billion ($10.7 billion) for the country annually, a top official said Wednesday. A majority of employees at His Majesty’s Revenue and Customs “are now saying…
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Bloomberg: Cook County’s Tax Foreclosure Scheme Violates US Constitution
Bloomberg, Cook County’s Tax Foreclosure Scheme Violates US Constitution: Cook County’s tax foreclosure scheme violates the Fifth and Eighth Amendments of the US Constitution, but the liability of the county still needs to be determined with further fact-finding, an Illinois federal court said. A class action showed Cook County’s tax foreclosure scheme deprived homeowners of…
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Newton Reviews Kleiman, Sarkar & Satterthwaite’s “Taxing Nannies”
Deanna S. Newton (Pepperdine) reviews Taxing Nannies by Ariel Kleiman (USC; Google Scholar), Shayak Sarkar (UC-Davis; Google Scholar), and Emily A. Satterthwaite (Georgetown; Google Scholar): Read the full review here. In Taxing Nannies, the authors Kleiman, Sarkar, and Satterwhite initiate an important conversation about the nanny tax by analyzing the preferences and perspectives of nannies themselves.…
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Osofsky Presents “Automated Agencies,” Co-Authored with Blank, at UNC Law Book Launch
Leigh Osofsky (North Carolina; Google Scholar) presents Automated Agencies: The Transformation of Government Guidance (Cambridge Univ. Press 2025), co-authored with Joshua Blank (UC–Irvine; Google Scholar), at a UNC Law book launch event on November 21, 2025: Speaking at a book release event on November 21, Osofsky detailed findings from Automated Agencies: The Transformation of Government Guidance. Federal agencies…
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Sam Presents “Taxation, Market Failure, and the Constitution” Today at Columbia
Erick J. Sam (Utah) presents Taxation, Market Failure, and the Constitution at Columbia today as part of its Davis Polk & Wardwell Tax Policy Colloquium hosted by Michael Love: If you would like a copy of the draft, please email Prof. Erick Sam, erick.sam@law.utah.edu, or Alykhan Pirani, anp2159@columbia.edu. The Colloquium will meet from 4:20 to 6:10 p.m. in room 103 of William…
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Bloomberg: IRS Issues Notice on Foreign Subsidiary Taxable Year Change
Bloomberg: IRS Issues Notice on Foreign Subsidiary Taxable Year Change: The IRS announced Tuesday it intends to issue proposed regulations on the 2025 GOP tax law’s elimination of a rule that allowed certain foreign subsidiaries of US companies to elect their tax year. Notice 2025-72 previews proposed regulations the agency will put out to clarify how…
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Bloomberg: IRS Seeks Comments on New Tax Credit for Education Scholarships
Bloomberg: IRS Seeks Comments on New Tax Credit for Education Scholarships: The IRS is seeking comments on a new tax benefit for donors who give to non-profits that expand access to private schools. Scholarship granting organizations typically provide scholarships for low-to-middle income K-12 students to attend private schools. Donors who give cash to these groups…
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Bloomberg: Treasury, IRS to Release Wave of New Guidance in Coming Months
Bloomberg, Treasury, IRS to Release Wave of New Guidance in Coming Months: Guidance documents on bonus depreciation, tax-exempt status, and international topics are among a barrage expected in the coming months from the Treasury Department and IRS, Ken Kies, assistant Treasury secretary for tax policy, told tax executives. The IRS is prioritizing guidance to implement…
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OECD updates Model Tax Convention to reflect rise of cross-border remote work and clarify taxation of natural resources
OECD, OECD updates Model Tax Convention to reflect rise of cross-border remote work and clarify taxation of natural resources: The OECD has released an update to the Model Tax Convention on Income and on Capital, providing new and detailed guidance on short-term cross-border remote work and on the taxation of income from natural resource extraction.…
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Bloomberg: Delaware Approves Business Tax Decoupling to Avoid Revenue Loss
Bloomberg, Delaware Approves Business Tax Decoupling to Avoid Revenue Loss: Delaware enacted legislation Wednesday to decouple the state from some federal business tax incentives after a debate over whether the move would drive businesses away from the small but corporate-friendly state. The Democratic-controlled Senate voted 14-6, along party lines, to approve H.B. 255, which Gov. Matt…
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Chodorow: “Saban, Pope, and the Benefits Theory of Taxation”
Adam Chodorow (Arizona State; Google Scholar), Saban, Pope, and the Benefits Theory of Taxation, 57 Ariz. St. L.J. 171 (2025): As a condition for receiving federal highway funding, Congress requires states to spend the revenues they raise from road users on the roads. Congress justified this condition, in part, because wanted federal money to supplement—not replace—state money…
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Osofsky: “Wellness and The Tax Law”
Leigh Osofsky (North Carolina; Google Scholar), Wellness and The Tax Law, 59 Ga. L. Rev. 443 (2025): The tax law has long provided extensive subsidies for “medical care.” These subsidies cost the government hundreds of billions of dollars a year. The definition of medical care, which is at the heart of these subsidies, originated many decades…
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Avi-Yonah: “Regulatory Taxation And The Tariffs”
Reuven S. Avi-Yonah (Michigan, Google Scholar), Regulatory Taxation And The Tariffs, U. of Mich. L. & Econ. Research Paper (forthcoming 2026): In Learning Resources Inc. v. Trump , the Supreme Court will decide whether the president has the authority under the International Emergency Economic Powers Act (IEEPA) to impose tariffs. The statute authorizes the president…
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JOTWELL: TAX: Crane reviews “Relics Reevaluated: How to think about Tariffs in a World Dominated by the Income Tax”
Charlotte Crane reviews Reuven Avi-Yonah (Michigan, Google Scholar), Doron Norotzki (Akron, Google Scholar), & Tamir Shana (College of Management, Google Scholar), From Relic to Relevance, The Resurgence of Tariffs, 77 U. Cal. L.J. __ (forthcoming 2026), available at SSRN (Mar. 10, 2025). There’s a lot of confusion about the justifications for and the consequences of…
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Harpaz: “Global Tax Wars in the Digital Era”
Assaf Harpaz (Georgia), Global Tax Wars in the Digital Era, 75 Am. U. L. Rev. 77 (2025): The digital economy fundamentally disrupts international tax principles that rely on physical presence. When a business earns income abroad, the country of residence (where the taxpayer resides) and the country of source (where income is generated) both have…
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Blue J is Hiring a Director of Tax Education
Blue J is hiring a Director of Tax Education: Blue J is the leading generative AI solution for tax professionals. As a B2B SaaS company, our customers are accountants and tax experts who rely on our market-leading software to deliver fast, accurate, and defensible answers to complex tax questions. With the launch of our flagship…
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Smith: “Abortion and State Taxes: Unexpected Parallelism”
Eric Smith (Weber State), Abortion and State Taxes: Unexpected Parallelism, 78 Okla. L. Rev. __ (forthcoming 2026): In 2018, South Dakota v. Wayfair, Inc., overruled the physical presence rule, a state and local tax doctrine requiring an out-of-state vendor to be physically present in a state before being compelled to collect the state’s sales and use…
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The New Status Quo For IRS Leadership Roles
Bloomberg, Acting or Vacant: The New Status Quo for Leadership Roles at IRS: Top jobs at the IRS in the Trump administration generally have two forms in 2025: vacant or acting. Roughly 30 jobs make up the top brass organizational chart at the agency. Of those, nine are vacant and 11 are filled by employees…