
Paul L. Caron
Dean
Pepperdine Caruso
School of Law

Michael Bologna (Bloomberg Law): Utah Takes Montana License Plate Fight to 80,000 Vehicle Owners At least 10 states — including Illinois, Maryland, and Minnesota — have adopted laws or enforcement initiatives in the past year targeting residents who register their cars, trucks, boats, and aircraft through Montana limited liability companies. California has leveled criminal tax…
September’s two-day Republican midterm convention may not have moved the needle among voters, but it did yield an interesting (and incredibly expensive) policy proposal from President Trump. “It will be called the Trump dividend,” said the President, as he floated a $5,000 government payout for all adult Americans, if Republicans retain control of both houses…
Forbes counts 50 billionaires in Sweden, a country of 10.6 million. That’s 4.7 billionaires per million inhabitants—almost double the rate in the United States (2.7). This statistic is in some tension with the country’s “normalizing force” of Jantelagen, the Scandinavian cultural code that discourages outward displays of personal success. With the global rise of the…
The New York State Bar Association’s Tax Section has recently released a new report, Report Number 1532 on Application of the Corporate Alternative Minimum Tax to Liabilities and to Distressed Taxpayers: [This Report] comment[s] on the application of the corporate alternative minimum tax (“CAMT”) under Sections 55, 56A, and 59 of the Internal Revenue Code…
Caitlin Reilly (Bloomberg Law): SALT Break Sought by New York, California Pays Off Across the US The expanded state and local tax deduction championed by New York lawmakers is gaining favor around the US, benefiting well-heeled taxpayers in states like Ohio, Colorado, North Carolina, Michigan and Pennsylvania. … Some counties in Florida and states in…
Chronicle of Higher Education, The Bob Jones Ruling Eats Its Own Tail: A DEI TAX: Go back to 1983. The U.S. Supreme Court ruled that the Internal Revenue Service could revoke Bob Jones University’s tax exemption because the religious institution’s prohibition on interracial relationships flouted “fundamental public policy” against racial discrimination. The Bob Jones decision was hailed by those who sought racial…
The limited expensing regime for qualified film or television productions expired at the end of 2025. Although a perennial tax extender until the Consolidated Appropriations Act, 2021 established the most recent sunset, the provision’s relatively low dollar cap left it somewhat anemic anyway. And with bonus depreciation generally triggered by release or broadcast, rather than…
This fall brings a number of ballot measures that will test the intuition that inflation breeds tax revolts. In the Wall Street Journal, Sanai Hadiya Rashid and Will Parker report: North Carolina, Wyoming, Florida and Oklahoma all have some kind of property-tax limit or rollback on the ballot this November. This follows bills passed in more…
Laura Saunders, How to Play the Retirement Tax Guessing Game (Wall Street Journal, Sept. 4, 2026) The great obstacle to effective tax planning for retirement funds is Congress. To make smart moves, savers need to know about future taxes—but this is impossible. Will lawmakers tackle $40 trillion of debt by raising rates, altering provisions or…
David Schultz (Bloomberg), Business Group Urges Tax Court to Stop Covid-19 Interest Accrual: Interest that accrued on unpaid taxes during the Covid-19 pandemic should be wiped out because of the text, structure, and history of a disaster relief statute, according to a brief filed in US Tax Court by the US Chamber of Commerce. The…
Andrew Duehren for the New York Times reports in “Audit Revenue Has Plummeted Under Trump, Watchdog Finds,” as follows: The amount of money the Internal Revenue Service collected from audits dropped dramatically last year after the Trump administration pushed out many of the agency’s employees, according to a watchdog report released on Monday. The report…
Cady Stanton, “IRS Funding Up in the Air Ahead of Deadline” (Tax Notes, August 31, 2026): The levels of both mandatory and discretionary funding for the IRS face an uncertain future as Congress returns from its August recess, and the fate of the agency’s annual funding likely won’t be determined until the end of the…
Brad Hooker (Bloomberg Law): California Fix for Montana Plates Tax Loophole Heads to Newsom California lawmakers are moving to shut down a tax maneuver that luxury vehicle owners use to avoid paying state taxes. The Assembly Wednesday approved a bill (SB 1406) by Sen. Jerry McNerney (D) to close what’s known as the “Montana loophole,” where…
Amy Hamilton (Tax Analysts): Alternative Apportionment: 2026 Flashpoints
Miriam Gottfried (WSJ): ‘A Roth IRA on Steroids’: Wealthy Americans Find Another Tax-Free Way to Invest Enter private-placement life insurance, a customizable insurance contract that allows unlimited investments to grow tax-free. “It is a Roth IRA on steroids for people who can afford it and want to leave it to their heirs,” said Jim White, founder…
New York Times DealBook, The A.I. Token Tax: When Bill Gates warned of the dangers posed by A.I. this week, he also weighed in on a somewhat obscure debate among politicians and economists about the best way to tax the technology. Gates suggested taxing A.I. tokens. This month, Representative Greg Casar of Texas, who chairs the Congressional Progressive…
It’s a myth that August is a quiet month for markets and politics. The same, apparently, is true for tariff policy and litigation, where August has brought a virtual heat dome of confluent events. The United States and Canada may be barreling towards “a full-blown trade war with no end in sight,” with potential legal…
After tax-deferred spin-off expansions in 2017 and 2023, Japan is considering additional deferral rules for sales of ancillary businesses, provided the proceeds are reinvested in core activities. The changes are modeled—at least ostensibly—on similar tax reforms in Germany in early 2000s that were intended to unwind the postwar Deutschland AG model. And they’re structural cousins…
Sarah Polcz (UC Davis) and Jeremy Bearer-Friend (George Washington University), An AI Tax Could Be the Great Equalizer America Needs, published in TIME: An idea that until recently would have been seen as radical—that the public should co-own AI—now commands bipartisan consensus. In June, Senator Bernie Sanders introduced the first AI tax in history, the American AI…
The Trump administration’s latest volley of tariffs include those imposed under section 301 and those imposed under section 338. The 50% tariffs now in effect on Canada (with more threatened on January 1) are putatively under the authority of section 338, and the replacement for the illegal IEEPA tariffs are putatively under the authority of…
Santhie Goundar, “Advisers Ponder Tax Issues Around Prince Harry’s Return to U.K.” (Tax Notes, Aug. 24, 2026): The news that Prince Harry and Meghan, the Duke and Duchess of Sussex, are returning to the United Kingdom from the United States sparked discussion among tax advisers about the timing of the move. . . . .…
DeAndre Morrow (Greenberg Traurig): Maryland Digital Ad Tax Rulings Shift Debate to What Comes Next, Bloomberg Tax (Aug. 21, 2026): Although the decisions may be viewed as taxpayer victories, they aren’t the final word and instead shift the controversy into its next phase. The comptroller has indicated that Maryland will continue defending the tax and intends…
Loukia Gyftopoulou, Paige Smith & Charlie Wells (Bloomberg): The Ultrawealthy Tax Maneuver That’s Spooking Schwab and Fidelity For months, the brokerage had piled into one of the hottest trades on Wall Street: “tax-aware long-short” accounts, which are helping legions of wealthy investors whittle down their tax bills. Millionaires love it so much they’ve poured roughly…
Peyton Rhodes (Bloomberg Law): ‘Taylor Swift Tax’ Draws Suit From Rhode Island Homeowners Rhode Island’s new tax on second homes disproportionately targets non-residents and has no reasonable basis for its selective application, according to a new suit challenging the tax on federal and state constitutional grounds. Dubbed the “Taylor Swift Tax” after the state’s famous…
Following up on my previous post, Colleges (and Law Schools) Await Looming IRS Guidance on Race and Admissions: Bloomberg Law, IRS Proposal on Race and Admissions Passes White House Review: IRS guidance on the application of fundamental public policy against racial discrimination in schools is one step closer to being released. The White House Monday…