Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax News
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UC Law SF Tax Prof Manoj Viswanathan to Serve as Interim Provost and Academic Dean
UC Law SF, Prof. Manoj Viswanathan Will Serve as Interim Provost & Academic Dean in 2027: After more than a decade of teaching, scholarship, and service at UC Law San Francisco, Professor Manoj Viswanathan is preparing to take on one of the College’s most important roles. Starting in January 2027, Viswanathan will serve as interim provost &…
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WSJ: When Your Bumper 401(k) Is a Tax Problem Waiting to Happen
Laura Saunders, When Your Bumper 401(k) Is a Tax Problem Waiting to Happen (Wall Street Journal, August 21, 2026) Here’s a good question for mid- and late-career workers: Do your traditional 401(k) or IRA accounts hold a large portion of your retirement savings? If the answer is yes, consider changes. While these accounts have advantages,…
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Update in the Limited Partner Litigation
As I’ve previously written, in January, the Fifth Circuit ruled in Sirius Solutions, LLLP v. Commissioner that the term “limited partner,” as defined in section 1402(a)(13) (the so-called “limited partner exception”) is “a partner in a limited partnership that has limited liability.” The government petitioned the Fifth Circuit to rehear the panel decision en banc,…
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Tax Noncompliance and the Gig Economy
Craig White and Matias Sokolowski (University of New Mexico), “Gig Economy Tax Noncompliance Comes at a Cost” (Tax Notes, Aug. 17, 2026): The rapid expansion of the gig economy has fundamentally reshaped the nature of work, income reporting, and tax compliance in the United States. Millions of individuals are earning income through platform-based apps as supplemental income or…
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Taxpayer Behavior in the Age of AI: A Field Experiment
Justin E. Holz (Michigan), Ricardo Perez-Truglia (UCLA), Andrew Simon (Virginia), and Alejandro Zentner (UT Dallas) have a new NBER working paper, “Taxpayer Behavior in the Age of AI: A Field Experiment on Property Tax Appeals” (August 2026). Here is the abstract: Navigating the tax system often requires information and judgment that taxpayers may lack. Although…
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Law Professor Appeals Remote Taxation Case to New York High Court
Cameron Browne (Tax Analysts): Law Professor Appeals Remote Taxation Case to New York High Court Zelinsky, a professor at the Benjamin N. Cardozo School of Law in New York City, filed a motion on July 20 to appeal the New York Supreme Court, Appellate Division’s July 2 decision in Zelinsky v. New York Commissioner of Taxation and Finance. In an…
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Trump Says US Weighing Attempt to Stop NYC Pied-A-Terre Tax
Hadriana Lowenkron (Bloomberg Law): Trump Says US Weighing Attempt to Stop NYC Pied-A-Terre Tax President Donald Trump said he would examine whether the federal government can stop New York City Mayor Zohran Mamdani’s new pied-à-terre tax, which was temporarily blocked by a state court. Trump in a social media post on Tuesday argued that the policy…
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Setting the Standard: A Major Development in Connecticut Domicile Cases
Timothy P. Noonan & Noah S. Chase (Hodgson Russ LLP), Setting the Standard: A Major Development in Connecticut Domicile Cases, 121 Tax Notes State 531 (Aug. 17, 2026) Over the years, we’ve spent a lot of time exploring the nuances of state tax residency and domicile issues in New York and other states. This is…
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Maryland Tax Court Invalidates Digital Ad Tax on Constitutional and ITFA Grounds
In what is possibly the most important state tax decision in the past two decades (aside from Wayfair), the Maryland Tax Court struck down Maryland’s digital advertising tax on Friday. The court held that the tax violated the Commerce Clause and Due Process Clause of the U.S. Constitution, and was also preempted by the federal…
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There May Be a Billion-Dollar Tax Play Hidden in the LA Lakers Sale, and It Probably Won’t Happen
The Los Angeles Lakers are changing hands again. Less than a year after Guggenheim Partners CEO Mark Walter acquired control of the team in a transaction valuing the Lakers at $10 billion, a group led by venture capitalist Josh Kushner and former Disney CEO Bob Iger reportedly has agreed to acquire the franchise at a…
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The Court of International Trade Upholds Trump’s Suspension of the De Minimis Tariff Exemption
On Thursday, August 13, the Court of International Trade (CIT), in a per curiam decision, upheld the Trump Administration’s suspension of an $800 de minimis exemption from duties and import taxes. The decision is Axle of Dearborn, Inc. v. Department of Commerce, Slip Op. 26-94, Court No. 25-00091 (Ct. Int’l Trade Aug. 13, 2026). The…
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WSJ: The Pros and Cons of Putting Extra Dollars in a Trump Account
Laura Saunders, The Pros and Cons of Putting Extra Dollars in a Trump Account (Wall Street Journal, Aug. 7, 2026) Trump accounts are here, and they’ve started with a bang. This year parents and others have signed up for more than seven million of these new, tax-favored savings accounts for children, according to the Treasury…
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The Tax Adviser: IRS provides guidance on rollovers between retirement plans and IRAs
Martha Waggoner (The Tax Adviser), IRS provides guidance on rollovers between retirement plans and IRAs: The IRS on Wednesday issued Notice 2026-49, which contains sample forms and proposed rollover procedures to simplify and standardize rollovers between retirement plans and individual retirement accounts (IRAs) as required by Section 324 of the SECURE 2.0 Act of 2022 (Division…
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Bloomberg: Highland Capital Says IRS Wrongly Taxed Great Recession Hedge
David Schultz (Bloomberg), Highland Capital Says IRS Wrongly Taxed Great Recession Hedge: A troubled securities trading firm says the IRS is improperly taxing a more than $166 million hedge it made at the outset of the Great Recession. Highland Capital Management filed a petition in US Tax Court Aug. 7 after the IRS readjusted its income for…
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N.Y. Times: Crocs Has a Trick for Dodging Taxes: a Tiny Office in Malta
In the New York Times, Jesse Drucker and Dylan Freedman have a new article, “N.Y. Times: Crocs Has a Trick for Dodging Taxes: a Tiny Office in Malta.” From the article: Take the stairs to the second floor of an old brewery on the Mediterranean archipelago of Malta and buzz yourself in to a tiny…
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California Budget & Policy Center: New Report on Proposed Billionaire Tax
The California Budget & Policy Center has a new report, “Billionaire Tax Explained: What Proposition 40 Would Mean for California” (Aug. 2026). Here is the “key takeaway”: Prop. 40 would institute a one-time 5% tax on the wealth of billionaires to raise tens of billions in temporary revenue to address the loss of federal funding…
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New York Judge Pauses Mamdani’s Second-Home Tax
Here is a New York Times report on the order and here is a PDF of the underlying complaint in the case. The theory of the complaint seem to be administrative and procedural: The underlying statute directs the city to make an “initial determination” that a property is not a primary residence for purposes the…
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Pied-à-Terre Owners Sue NYC, Seek to Avoid Tax
Chris Dolmetsch (Bloomberg Law): Mamdani Handling of Pied-à-Terre Tax Contested by Homeowners New York City was sued by a group of homeowners seeking to delay the rollout of Mayor Zohran Mamdani’s new pied-à-terre tax, saying the publication of a list of properties that could be subject to the levy has caused “mass confusion” and invited “unwarranted…
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Trump’s Latest Tariffs Hit With New Lawsuit by 25 States
Erik Larson (Bloomberg Law): Trump’s Latest Tariffs Hit With New Lawsuit by 25 States A group of 25 states filed a lawsuit challenging President Donald Trump’s new global tariffs that went into effect last month, adding to similar complaints by small businesses who claim the levies are illegal. New York, California, Illinois and other states…
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The Supreme Court’s 2025 Term in Tax
Jasper L. Cummings, Jr. (Alston & Bird), The Supreme Court’s 2025 Term in Tax, 192 Tax Notes Fed. 867 (Aug. 3, 2026): This is my 15th annual review of Supreme Court opinions relevant to state and federal taxation. As usual, other conflicts crowded out the tax cases except for the one big one addressing tariffs, which was of…
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View from Practice: Goldstein Sentencing and Appeal
The trial is over. The sentence is in. The appeal has begun. On July 24, 2026, Tom Goldstein, superstar Supreme Court advocate and founder of SCOTUSblog, was sentenced to six years in federal prison following his conviction on nine tax counts and three mortgage fraud counts. What explains Goldstein’s sentence? What are Goldstein’s prospects on…
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Zac Brown Band Fenway Park Free Cruise Giveaway
I’m just going to leave this here without comment. (Tax profs looking for fresh hypos for your Federal Income Tax classes, please enjoy…) Ben Zimmoneau, Free cruise from Zac Brown comes with hundreds in expenses (WCVB, Aug 4, 2026) Zac Brown surprised 37,000 fans at a sold-out Fenway Park concert Sunday night by announcing what…
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WSJ: Missouri Voters Defeat Measure to Abolish Income Tax
Jeanne Whalen, Missouri Voters Defeat Measure to Abolish Income Tax (Wall Street Journal, Aug. 5, 2026) Missouri residents overwhelmingly defeated a ballot measure that would have allowed lawmakers to eliminate the state income tax and replace it with higher sales taxes, breaking with other Republican-led states that have slashed income taxes. The lopsided vote against the…
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The Tax Adviser: Effect of the new pro rata share rules
Elizabeth Nelson (CPA,), J.P. Gregory (CPA), and Katrelle Harvey: Effect of the new pro rata share rules: Recent changes to the rules related to the deduction for certain foreign dividends received by U.S. corporate shareholders could substantially reduce the abuse concerns that the extraordinary reduction (ER) rules were designed to address, but the ER rules’ compliance…