Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax News
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Prop 40, Meta, and The Future of Taxation in America
The Dispatch, California’s Billionaire Tax Is Changing the World: On October 21, Meta announced a 2-for-1 stock split, meaning that every Meta shareholder gets a second share for each one that they own. … [I]f you read the 109-page filing, you’ll find that the split wasn’t really about the share price (or pursuing acquisitions, etc.,…
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Higher Ed Groups Condemn Proposed IRS Reg to Revoke Tax Exempt Status of Private Colleges That Discriminate
Inside Higher Ed, Higher Ed Groups Condemn Proposal That Could Ax Private College Tax Exemptions: The IRS says “all forms” of racial or ethnic discrimination could trigger loss of tax-exempt status under the regulation, “regardless of the intent behind or the legality of such discrimination.” Organizations say they fear political abuse. Higher education advocacy groups…
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Do Tax Havens Win Under Pillar 2?
The Financial Times reports that long-time corporate tax havens Guernsey, Jersey, and Bermuda anticipate substantial corporate tax windfalls under the OECD’s global minimum tax, notwithstanding earlier concerns that higher taxes would encourage multinationals to decamp the jurisdictions. But does this result show that Pillar 2 is working as intended, or will Pillar 2 facilitate another…
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ITEP: 114 Large Corporations Paid No Current Federal Income Tax in 2025
In 2017, the TCJA lowered headline corporate tax rates and expanded business tax benefits. Federal corporate tax receipts, however, remained largely buoyant, fueled in part by record-setting post-pandemic growth among large companies. Then, the OBBBA doubled down on tax benefits for investment and R&D, while loosening guardrails such as limitations on interest expense deductions. Has…
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Zidar and Zwick: “There’s a Much Better Way to Make Rich People Pay Their Share”
Owen Zidar (Princeton) and Eric Zwick (Chicago Booth) have a new Op-Ed in the New York Times titled “There’s a Much Better Way to Make Rich People Pay Their Share.” From the piece: Policymakers keep adding groups to the list of loophole beneficiaries: incumbent homeowners, venture capital and private equity partners, everywhere millionaires, heirs and,…
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Update on Tariff Challenges
Challenges to President Trump’s various invocation of tariff policies have multiplied, and I figured I would give an update on where each of the challenges currently stands. Section 122 Tariffs These were the tariffs that were imposed in the wake of the President’s loss in Learning Resources, Inc. v. Trump. They expired after 150 days…
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Musk Would Avoid $2 Billion Tax Bill With Trump Account Donation
Chris Cioffi (Bloomberg Law): Musk Would Avoid $2 Billion Tax Bill With Trump Account Donation Elon Musk’s enormous promise to give a SpaceX share to every child in America could vaporize around $2.6 billion in taxes for Musk….And though receiving stocks in Trump Accounts could be a good deal for holders of the tax-privileged accounts,…
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Tax Prof Masterminds of California Wealth Tax Bet Their Moment Has Arrived
Bloomberg, Tax-the-Rich Masterminds Bet Their Moment Has Finally Arrived: When Senator Elizabeth Warren ran for president in 2020, she suggested making America’s richest households pay a tax on their wealth. David Gamage was one of the people called in to work on it. Gamage, a University of Missouri tax law professor who worked in the…
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IRS Hiring Spree Signals Enforcement Shift, Targets Wealthy
Bloomberg Law, As IRS Hires Again, Private Sector Watches for Enforcement Shift: A renewed hiring effort from the IRS in its compliance divisions is signaling to the private sector that it isn’t shying away from enforcement. IRS Chief of Compliance Jarod Koopman said last week the IRS is hiring roughly 1,000 workers for the small…
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The IRS Has a $180 Million Ghost-Preparer Problem
Ghost preparers have long haunted the United States’ tax system. In the mid-1970s, employees at the ten IRS service centers sorted incoming returns into “fats and flats“—thick envelopes stuffed with multiple returns, compared to slim(mer) single-return mailings. Employees then examined the contents of the “odd” deliveries “to see whether the returns were signed by a…
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Pigou Returns! Halloween Edition
It’s Halloween, and the media (and Reddit) are talking candy! Prices are up, and sales are down—for large and extra-large bags. Small bags? Sales are up, in total dollar terms. In the age of affordability, consumers may be more discerning, according to Sally Lyons Wyatt, a global executive vice president and food industry adviser for…
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Jotwell: Tax : The Billionaire Tax: Dispassionate Analysis of a Policy that We Desperately Need
Neil H. Buchanan (Florida), Tax : The Billionaire Tax: Dispassionate Analysis of a Policy that We Desperately Need (reviewing Brian Galle, David Gamage, Emmanuel Saez, and Darien Shanske, Expert Report on the California 2026 Billionaire Tax: Revenue, Economic, and Constitutional Analysis): California and New York City are the current epicenters of efforts to slightly increase…
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N.Y. Times: Inside the Billionaires’ War Against California’s Proposed Wealth Tax
In the New York Times, Theodore Schleifer and Erin Griffith have a report, “Inside the Billionaires’ War Against California’s Proposed Wealth Tax.” From the article: Every Tuesday for the last few months, two dozen of the world’s richest people or their advisers hop onto a conference call and plan for war. The war is against…
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Mark Zuckerberg Plots Deal to Pay Wealth Tax, Keep Meta Control
Anders Melin (Bloomberg Law): Mark Zuckerberg Plots Deal to Pay Wealth Tax, Keep Meta Control Mark Zuckerberg’s months of wrangling with his own board came to a head with a dinner-table ultimatum. … His announcement came on Sept. 9, during the board’s regularly scheduled dinner. He was taking steps to leave California after the wealth-tax…
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Goldman’s $2.3 Billion Deal Puts Tax-Smart ETFs Under Scrutiny
Lu Wang & Justina Lee (Bloomberg Law): Goldman’s $2.3 Billion Deal Puts Tax-Smart ETFs Under Scrutiny When Goldman Sachs Group Inc. buys boutique ETF provider Neos Investments, it’ll acquire not only some of the hottest derivative-income funds around, but also products that are testing how decades-old laws are applied to Wall Street’s new generation of…
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TIGTA: 2.2 Million Tax Returns Prepared Using Noncompliant PTINs
The Treasury Inspector General for Tax Administration has identified more than 38,000 paid tax-return preparers with noncompliant preparer tax identification numbers (PTINs) who prepared more than 2.2 million returns for the 2025 return-processing season. The IRS requires individuals to have current PTINs to prepare tax returns for compensation, and PTINs must be reported on tax…
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Bloomberg: Basketball Player in Japan Says He Deserves Foreign Credits
Bloomberg (David Schultz), Basketball Player in Japan Says He Deserves Foreign Credits: A professional basketball player who played in Japan sued the IRS in US Tax Court, contesting the agency’s rejection of more than $1.28 million in foreign tax credits he claimed on his 2020 and 2021 federal returns. Ryan Rossiter, who has played professional…
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Mamdani’s Pied-à-Terre Tax Hits Wealthy Out-of-Towners With a Double Whammy
James Fanelli, Deborah Acosta & Caitlin Ostroff (Wall Street Journal): Mamdani’s Pied-à-Terre Tax Hits Wealthy Out-of-Towners With a Double Whammy As the Mamdani administration looks to levy the new tax and increases scrutiny of where the city’s elite reside, some face an unwelcome double whammy as they also stand to lose an abatement that shaves…
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Ireland’s Tax Cuts, Financed by a Corporate-Tax Windfall
As EU members face fiscal austerity under the revised Stability and Growth Pact, Ireland finds itself an outlier. In early October, Ireland’s government proposed a budget rife with household-oriented tax breaks and spending supports. On the table: lower indirect taxes on gasoline and heating fuels, increased income-tax bracket cutoffs and personal credits, enhanced housing benefits,…
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Roundup: Changing Coalitions and California’s Billionaire Tax
It’s mid-October, and spending to oppose California’s proposed billionaire tax has breached $1 million per day. Some polling indicates that the ballot measure has a “slim” edge among likely voters, with a potentially significant slice of the electorate undecided. But Propositions 41 and 42—the pair of counterinitiatives to Proposition 40—also have more voter support than…
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2026 Sacramento Delegation: State and Local Tax Policy Discussion
2026 Sacramento Delegation on October 16 @ 10:30 am – 3:30 pm:
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Luke: ‘Transaction’ as Threshold, ‘Relevant’ as Directive in the Economic Substance Doctrine
In Tax Notes, Charlene Luke (Florida) critiques the dissenting opinion in the recent Tenth Circuit decision, Liberty Global Inc. v. United States, in which the majority ruled in favor of the government on the economic substance doctrine. From the piece: Much has already been written about Liberty Global, which involved a complex transaction called Project…
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How Meta Uses A.I. Data Centers to Avoid Billions in Federal Taxes
Kashmir Hill, Jesse Drucker, Eli Tan & Mike Isaac (New York Times): How Meta Uses A.I. Data Centers to Avoid Billions in Federal Taxes Mark Zuckerberg says Meta’s A.I. push is a tremendous success. “Our investments in A.I. are accelerating every major part of our core business,” he has told investors. “Every sign that we’re…
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State AGs Say New Proposed H-1B Visa Charge Is Unconstitutional Tax
Paul Jones (Tax Analysts): State AGs Say New Proposed H-1B Visa Charge Is Unconstitutional Tax The Trump administration’s newest proposed fee on H-1B visas is an unconstitutional tax that is outside its authority to promulgate, according to attorneys general of 22 states, led by California and Massachusetts. The fee — proposed under August 25 rulemaking…
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SALT Cap Quirk Turns Couples Off Marriage
Bloomberg Law, SALT Cap Has Couples Ditching Marriage to Save $20,000 in Taxes: A quirk of the new tax code means [couples] could potentially deduct twice as much from their income if they were to legally split up and file their taxes as singles. President Donald Trump’s tax cuts last year increased the limit on…