Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax News
-
Politico: IRS CEO Defiant as Washington Asks Who’s Running Things
This week, Politico has an exclusive interview with Frank Bisignano, who serves as Commissioner of the Social Security Administration and as the “newly invented” Chief Executive Officer of the IRS. Politico’s report also includes comments from six IRS employees on Bisignano’s tenure. Next up: Bisignano’s scheduled appearance at a Tax Day Senate hearing. Links and
-
WSJ: The High-Tax Wealth Flight Continues
Wall Street Journal, Editorial Board, The High-Tax Wealth Flight Continues (March 27, 2026), As Democrats across the country seek to raise income taxes, the IRS on Friday released new data on state income migration that is a reality check on their ambitions. Even after the pandemic, high-tax states continue to lose tens of billions of
-
NY Times: Justice Dept. Struggles to Respond to Trump’s Suit Against I.R.S.
In a previous post on TaxProf Blog, we had highlighted President Trump’s lawsuit against the IRS. In an article in The New York Times, Andrew Duehren and Alan Feuer report: The Justice Department is struggling to decide how to respond to President Trump’s lawsuit demanding at least $10 billion from the I.R.S., as the department’s
-
Derek Thompson: America’s Tax System Is Broken
On Derek Thompson’s Plain English podcast, he interviews Gabriel Zucman (Paris School of Economics, UC Berkeley) about the current state of the American tax system and on how a wealth tax might address some of the concerns raised. From the podcast’s summary: If you’re a typical worker with a salary, you have almost no control
-
State QSBS Conformity
State conformity to the federal tax code is a messy and constantly evolving process. The conformity stakes are raised exponentially when Congress enacts substantial tax preferences, as it did in 2017 with the TCJA and again last year with the OBBBA. Despite the Treasury Secretary’s reproach, almost all states will decouple from certain federal tax
-
Washington State’s Odd Place in the Millionaire’s Tax Debate
Billy Hamilton (Tax Notes): Washington State’s Odd Place in the Millionaire’s Tax Debate Flying in the face of this long history of failure, the Democrat-controlled Legislature is taking another swing at the elusive income tax this year, but they’re proposing not a general income tax, but one that targets the state’s richest taxpayers: a millionaire’s
-
NY Times: They Want to Stop Paying Taxes as a Protest. There Are Consequences.
Tara Siegel Bernard, They Want to Stop Paying Taxes as a Protest. There Are Consequences, N.Y. Times (Mar. 22, 2026): “How can I pay taxes when I don’t want to pay for things I abhor, while neglecting things I care about?” asked [a retired chaplain in Sonoma, California], who objects to paying for immigration detention
-
New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released three new reports concerning (1) the 2026-2027 New York State Executive Budget, (2) Section 355 Private Letter Ruling Policies, and (3) Proposed Updates to the Internal Revenue Service Voluntary Disclosure Practice:
-
The Road Ahead for Trump’s Tariff Refunds
Michael Smith, “The Long, Winding Road for Trump’s Tariff Refunds” (Tax Notes, March 24, 2026): U.S. Customs and Border Protection (CBP) has presented a plan for providing tariff refunds that offers some hope that importers will be able to receive a prompt refund — but several questions remain unanswered. . . . . CBP filed
-
House Ways and Means and Senate Finance Committees to Lose Experience After Midterms
Bloomberg Law: Powerful Tax-Writing Panels to Lose Experience After Midterms High-profile retirements and competitive elections among senior tax writers will likely give the House Ways and Means Committee a new look next Congress. The Senate Finance Committee, the chamber’s counterpart to Ways and Means, only has three members who have announced their plans to retire.
-
California Bill Proposes 50% Gross Receipts Tax on Private Immigration Detention Facilities
Bloomberg Law: Immigration Facility Contractors Warn on California Tax Proposal The bill (A.B. 1633) from Assemblymember Matt Haney (D) would levy a 50% tax on gross receipts from contracts to operate private immigration detention facilities in California. There are two companies that do such work in the state, according to the bill sponsor’s office: CoreCivic Inc. and
-
What the xAI Acquisition Means for a SpaceX IPO
Elon Musk’s SpaceX is reportedly exploring a mid-2026 IPO that could rank as the all-time largest in nominal dollars and catapult SpaceX’s valuation well into the trillion-dollar club. Add in the company’s sci-fi-to-reality approach and controversial founder, and a SpaceX IPO would be the highest-profile deal of the summer. February brought a teaser of this
-
Treasury “Considering All Options” for Proposed § 892 Regs
In mid-December 2025, Treasury issued proposed and final regulations under § 892 that could impose additional burdens on sovereign wealth funds’ investments in the United States, including in the currently volatile private credit market. This latest iteration in the long-running guidance project under § 892 stood in some tension with the Trump Administration’s efforts to
-
Updates on the Limited Partner Exception Litigation
In a previous post on TaxProf Blog, I highlighted the Fifth Circuit’s decision in Sirius Solutions, LLLP v. Commissioner in holding that the limited partner, as defined in section 1411(a)(13) (the so-called “limited partner exception”) is “a partner in a limited partnership that has limited liability.” I also noted that the First Circuit is reviewing
-
WSJ: Red and Blue States Are Growing Further Apart on Income Tax
Richard Rubin & Jeanne Whalen (WSJ): Red and Blue States Are Growing Further Apart on Income Tax GOP-led states are looking to entice new residents with lower taxes, while Democratic-led states seek higher taxes on top earners to shore up budgets and social services
-
Chicago’s Social Media Tax Faces First Legal Challenge
Perry Cooper (Bloomberg Law): NetChoice Files First Case Over Chicago’s Social Media Tax The tech industry trade association NetChoice filed the first challenge to Chicago’s first-in-the-nation tax on social media companies Friday, telling a state trial court the levy is preempted by federal law and violates the US and Illinois constitutions. The complaint is asking the Illinois
-
Washington State Legislature Approves Millionaire’s Tax
Tax Notes: Washington Legislature Approves Millionaire’s Tax Washington lawmakers have approved a new income tax on millionaires, securing a key legislative victory for progressive tax reformers. S.B. 6346 is set to be signed by Gov. Bob Ferguson (D), likely setting the stage for a legal fight before the state supreme court and a potential ballot repeal effort by
-
Bessent’s Term as Acting IRS Commissioner Expires
Treasury Secretary Scott Bessent’s 210-day stint as Acting IRS Commissioner expired in early March 2026. The Federal Vacancies Reform Act precludes Bessent from continuing in that specific temporary role. The IRS says that there will be more continuity than change, however. On March 13, 2026, a news release clarified leadership responsibilities at the IRS going
-
Washington Post: Many Wealthy Americans Already Pay European Tax Rates
Washington Post, Many Wealthy Americans Already Pay European Tax Rates (Editorial Board, March 11, 2026) Listening to far-left politicians clamor for wealth taxes on Americans may leave some with the mistaken impression that the rich don’t pay their fair share. In truth, while the United States generally has lower income taxes than rich European countries,
-
Section 122 Tariffs Challenged in the Court of International Trade
In the wake of the Supreme Court’s decision in Learning Resources, Inc. v. Trump, which held that IEEPA does not authorize the President to impose tariffs in the event of a national emergency, the Trump administration immediately sought to implement across-the-board 10% tariffs under a different statute, known as “section 122 tariffs.” On Thursday, March 5, twenty-two states
-
Freedom Path v. IRS Amicus Brief
Professor Donald Tobin (Maryland) just filed an amicus brief in Freedom Path, Inc. v. IRS, where the D.C. district court determined that the IRS regulation regarding 501(c)(4) and the primary purpose standard are unconstitutionally vague. From the brief’s summary of argument: In light of the Court’s decision that the regulations and rulings at issue are
-
Booker Proposes $75,000 Standard Deduction
Katie Lobosco, “No Tax on $75,000 of Income? Dem Proposes Big Standard Deduction” (Tax Notes, March 10, 2026): Sen. Cory A. Booker, D-N.J., is unveiling a new tax plan that would more than double the standard deduction, increase the child tax credit and earned income tax credit, and raise the corporate tax rate. The legislative
-
MTC Fights Federal Intervention in Hawaii Cruise Ship Tax Case
Amy Hamilton (Tax Notes): MTC Fights Federal Intervention in Hawaii Cruise Ship Tax Case The Multistate Tax Commission is urging the Ninth Circuit to reject the U.S. Justice Department’s intervention in a Hawaii tax dispute as improper overreach that could let the federal government sidestep the Tax Injunction Act. In a February 25 amicus brief in Cruise Lines International Association Inc. v. Suganuma,
-
2026 World Cup Tax Implications
Bloomberg Law: FIFA 2026 World Cup Blows the Whistle on Complex Tax Risks The 2026 FIFA World Cup will take place in North America this summer, jointly hosted by the US, Canada, and Mexico. This expanded tournament will feature 48 teams, bringing together a diverse array of nations and fans for a truly global celebration.
-
Colleges (and Law Schools) Await Looming IRS Guidance on Race and Admissions
Bloomberg Tax, Colleges Await Looming IRS Guidance on Race and Admissions: Private colleges and universities with programs aimed to benefit racial minorities are girding themselves for new rules governing their tax-exempt status after a year of increased scrutiny by President Donald Trump. The administration, which plans to issue guidance in the next year, has cracked down on what it