Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax News
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IRS Offers To Settle Cryptocurrency Case, But Taxpayer Wants Precedent That Mining/Staking Is Not A Realization Event
Press Release, Taxpayer Lawsuit Demands Confirmation of Tax Treatment of Staking Rewards: Today, the Proof of Stake Alliance (POSA), a leading blockchain industry association, celebrated important news: as part of ongoing federal litigation (Jarrett v. United States, No. 3:21-cv-00419 (M.D. Tenn.)), the government has offered to refund plaintiff Joshua Jarrett for the taxes he paid when he created new…
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Tax-Free Inheritances Fuel America’s New $73 Trillion Gilded Age
Bloomberg, Tax-Free Inheritances Fuel America’s New $73 Trillion Gilded Age: Almost half of all U.S. wealth transferred over the next quarter century will come from the top 1.5% of households. Americans can expect to inherit $72.6 trillion over the next quarter century, more than twice as much as a decade ago, in the latest indication…
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Jeff Bezos’s $200 Million, 50-Year Naming-Rights Deal With The Smithsonian Does Not Include A ‘Morals Clause’
MarketWatch, Exclusive: Jeff Bezos’s $200 Million, 50-Year Naming-Rights Deal With the Smithsonian Does Not Include a ‘Morals Clause’: Amazon.com founder Jeff Bezos’s name will be displayed on a new building at the National Air and Space Museum and in several additional places throughout the Smithsonian Institution for at least 50 years in exchange for his…
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The IRS Wants To Scan Your Face
Washington Post, IRS Wants to Scan Your Face: Millions of Americans will soon have to scan their faces to access their Internal Revenue Service tax accounts, one of the government’s biggest expansions yet of facial recognition software into people’s everyday lives. Taxpayers will still be able to file their returns the old-fashioned way; the IRS…
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U.S. Tax Court’s Tax Trailblazers: Judge Mary Ann Cohen
U.S. Tax Court's Diversity & Inclusion Series, Tax Trailblazers: Mentoring the Next Generation: Please join the United States Tax Court as its Tax Trailblazers series continues with Chief Judge Maurice B. Foley interviewing Judge Mary Ann Cohen, the Tax Court’s first female Chief Judge. Today at 7:00-8:15 PM EST (register here). Judge Mary Ann Cohen…
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WSJ: The Huge Tax Bills That Came Out Of Nowhere At Vanguard
Wall Street Journal, The Huge Tax Bills That Came Out of Nowhere at Vanguard: It’s easy for a small investor to make big mistakes. It would be even easier for giant investment firms to help prevent them—but, sadly, the asset-management industry seems to have other priorities. Just look at what happened last month to some…
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IRS Targets Your Side Hustle In Crackdown On Transactions Over $600
Bloomberg, IRS Targets Your Side Hustle In Crackdown on Transactions Over $600: It just got harder to hide from the IRS. Starting this month, users selling goods and services through such popular sites as Venmo, Etsy and Airbnb will begin receiving tax forms if they take a payment of more than $600. One by one…
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Americans For Tax Fairness Seeks To Hire A Tax Research & Policy Associate
Americans For Tax Fairness is seeking to hire a Tax Research & Policy Associate: POSITION SUMMARYAmericans for Tax Fairness, a coalition of national and state endorsing organizations active on high-profile federal tax reform issues, is seeking a Research & Policy Associate to provide support for research, policy and communications work and perform administrative duties. This…
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NY Times: The IRS Is Warning Of A Messy Tax Season
New York Times, The I.R.S. Is Warning of a Messy Tax Season: The federal tax filing season will run from Jan. 24 to April 18 this year, the Internal Revenue Service said on Monday, warning in its announcement that staffing shortages and paperwork backlogs could make for a messy and frustrating experience for taxpayers. In…
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Morse: A Tax Deadline Missed By One Day Leads To A Supreme Court Showdown Over Equity, Jurisdiction – And Grammar
SCOTUSblog: A Tax Deadline Missed By One Day Leads to a Showdown Over Equity, Jurisdiction – and Grammar, by Susan C. Morse (Texas; Google Scholar): The argument on Wednesday in Boechler v. Commissioner of Internal Revenue will consider whether “equitable tolling” — which allows courts to excuse missed deadlines in some circumstances — is available for a…
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ABA Tax Section Seeks Nominations For Janet Spragens Pro Bono Award
The ABA Tax Section is soliciting nominations for the 2022 Janet Spragens Pro Bono Award: The Tax Section pleased to announce that we are accepting nominations for the 2022 Janet Spragens Pro Bono Award given to an individual or law firm for sustained and outstanding achievements in pro bono activities in the tax law. Find the nomination form here. The criteria…
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Grewal: Lobbying The Tax Court
Andy Grewal (Iowa; Google Scholar), Lobbying the Tax Court: As many litigators know, federal courts often take substantial time before they rule on motions or issue their opinions. Weeks, months, or sometimes even years may pass between an argument over an issue and a court’s disposition of that issue. Parties usually have little choice but…
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Tax: One Of The 20 Hottest Law Jobs For The Next Decade
The 20 Hottest Law Jobs for the Next Decade, Nat'l Jurist, Fall 2021, at 18: [I]t’s hard to predict which areas of law will become most in demand, because it’s hard to predict where society is headed. … We turned to top experts, the three authors of Law Jobs: The Complete Guide, to get their…
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The Top 10 Tax Posts Of 2021
Bryan Camp (Texas Tech), Lesson From The Tax Court: S Corp Payments To Sole Shareholder Were Wages Bryan Camp (Texas Tech), Classic Lesson From Tax Court: The Convenience Of The Employer Doctrine New York Times, With Higher Taxes Possible, Here’s What To Do Now Bryan Camp (Texas Tech), Lesson From The Tax Court: The Structure…
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New State Business Tax Climate Index: Blue States Are Worst, Red States Are Best
Following up on Thursday's post, New U.S. Census Data: Major Migration From Blue States To Red States, which noted that 9 of the 10 states with the largest population losses voted for Joe Biden in 2020, and 8 of the 10 states with the largest population gains voted for Donald Trump: Tax Foundation, 2022 State…
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New U.S. Census Data: Major Migration From Blue States To Red States
U.S. Census Bureau, New Vintage 2021 Population Estimates Available for the Nation, States and Puerto Rico: According to the U.S. Census Bureau’s Vintage 2021 national and state population estimates and components of change released today, the population of the United States grew in the past year by 392,665, or 0.1%, the lowest rate since the nation’s…
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NY Times: Section 1202 Qualified Small Business Stock — A ‘Preposterous’ Tax Dodge For The Ultrawealthy
New York Times, The Peanut Butter Secret: A Lavish Tax Dodge for the Ultrawealthy: A tax break aimed at small businesses has become a popular way for Silicon Valley founders and investors to avoid taxes on their investment profits. This is the story of the incredible cloning tax break. In 2004, David Baszucki, fresh off…
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A Year Of Lessons From The Tax Court (2021)
Here is a chronological listing of all the Lessons From The Tax Court I posted in 2021, with links to, the Lesson, the primary case discussed and its author. I have also listed the primary Code sections mentioned or discussed in the Lesson. At the end of the chronological listing, you will find a table…
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Graetz: Tax Policy’s Bipartisan Roots
Michael J. Graetz (Columbia) received the Tax Foundation's 2021 Distinguished Service Award (press release) and gave a speech on Tax Policy’s Bipartisan Roots: I always begin my classes in Federal Income Taxation by reminding my students that the tax law is the primary link between people and their government—they all will have to wrestle with…
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WSJ: The Internal Revenue Leak Service
Wall Street Journal editorial, The Internal Revenue Leak Service: Democrats want to give $80 billion to the Internal Revenue Service to audit millions of Americans each year. Yet six months after the progressive website ProPublica first published the secret tax information of rich Americans, the tax agency still can’t explain what happened. Senate Republicans led…
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ProPublica: How Three Families Shielded Their Fortunes From Taxes For Generations
ProPublica, The Great Inheritors: How Three Families Shielded Their Fortunes From Taxes for Generations: In the early 1900s some of the wealthiest Americans claimed their fortunes would never last through the generations. A century of tax avoidance later, the dynasties are going strong. President Franklin D. Roosevelt pounded on his desk and swore. His treasury…
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Treasury Department Plans First Analysis of U.S. Tax Benefits By Race
Bloomberg, Treasury Plans First Analysis of U.S. Tax Benefits by Race: The U.S. Treasury is launching an effort to examine the distribution of federal benefits and taxation by race, starting with a look at the pandemic relief payments that were due to most American households. Deputy Treasury Secretary Wally Adeyemo, along with Lily Batchelder, the…
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Year-End Charitable Giving Tax Advice From The NY Times And WSJ
New York Times, There’s Still Time to Get a Tax Break for Donations to Charity Wall Street Journal Tax Report, Making Year-End Donations? Get the Most Tax Bang for Your Charity Buck
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The Whiteness Of Tax And How To Narrow The Race Gap
Amanda Athanasiou (Tax Notes), The Whiteness of Tax and How to Narrow the Race Gap: Tax is probably not at the top of anyone’s list of the most diverse legal professions, nor should it be. The 2020 U.S. census revealed a more racially diverse population than was measured a decade earlier, with Black or African…
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219 Economists & Law Professors Urge Congress To Include The ‘Billionaires Income Tax’ In Build Back Better Act
Americans For Tax Fairness, 219 Economists & Law Professors Urge Congress to Include the “Billionaires Income Tax” in Build Back Better Act: Open Letter Argues the Levy on Billionaire Wealth Growth Would Ensure Nation’s Richest Are Included in Tax Reform Nearly 220 economists, law profssors and other scholars on the economy today sent a letter to…