Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax News
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Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case
David Schultz & Michael Rapoport (Bloomberg Law): Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case A panel of federal appellate judges were receptive to Coca-Cola Co.’s arguments that the IRS improperly allocated its foreign income in a case that could cost the soft drink company up to $20 billion.
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NY Times: Congress Should Reform Endowment Tax to Incentivize More Wealthy Colleges to Expand Access to Working- and Middle-Class Students
New York Times Op-Ed: A Bold Idea to Open Up Elite Colleges, by James S. Murphy (Fellow, Class Action) & Ryan Cieslikowski (Co-Founder & Director, Class Action): Princeton recently waived tuition for most students from families making up to $250,000 a year. Reporting in The Daily Princetonian suggests that this move may have removed the university from…
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Trump Threatens 100% Tariffs in Response to European DSTs
In another iteration of the Trump Administration’s long-running opposition to digital services taxes, President Trump on Friday threatened to impose 100% tariffs on all imports from countries that impose or move forward with DSTs. Trump said that the tariff would supersede other trade agreements—most centrally the deal struck last year with the European Union that…
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TIGTA: The IRS Provided Addresses for Nearly 47,000 Persons to ICE
In early June, the Treasury Inspector General for Tax Administration released a lightly redacted report on the IRS’s implementation of its April 2025 data-sharing agreement with the Department of Homeland Security and U.S. Immigration and Customs Enforcement. The report focuses on the IRS’s processes and controls for responding to ICE requests for taxpayer address information,…
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WSJ: California’s Billionaire Tax Kicks Off a Democratic Civil War
Paul Kiernan and Laura J. Nelson, California’s Billionaire Tax Kicks Off a Democratic Civil War (Wall Street Journal, June 25, 2026) California’s proposed billionaire tax will appear before voters in November, teeing up a fight among Democrats over wealth, affordability and the future of their party as they push to take back Congress in this…
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Taxpayer Advocate Service: Releases FY 2027 Objectives Report to Congress
Taxpayer Advocate Service: Advocate Service: Releases FY 2027 Objectives Report to Congress: The Internal Revenue Code requires the National Taxpayer Advocate to submit two annual reports to the House Committee on Ways and Means and the Senate Committee on Finance. The National Taxpayer Advocate is required to submit these reports directly to the Committees without…
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Federal Circuit Permits Section 122 Tariffs to Proceed
In a per curiam order, the Federal Circuit ruled that that the tariffs imposed under section 122 of the Trade Act of 1974 could continue to be collected. The order was in response to a motion to stay the judgment of the Court of International Trade, which had ruled the tariffs were unlawful back in…
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Clouse et al.: California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits
In Tax Notes, Jim Clouse, Fabio Natalucci, Charles W. Calomiris, Kenneth Rosen, David Bank, and Maxwell Hall, have written a new piece, “California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits.” From the introduction: The dire fiscal outlook for the state of California has prompted numerous proposals for ways to increase state…
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Tax Law Center: How Congress Should Quickly Block the President’s Get-out-of-Tax-Free Card
Brandon DeBot and Kelsey Merrick from the Tax Law Center have published a new blog post, “How Congress Should Quickly Block the President’s Get-out-of-Tax-Free Card.” From the piece: Members of Congress and observers across the political spectrum have criticized the Administration’s attempts to give the President, his family, and his affiliates an extraordinary release of…
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Supreme Court Tells Us What “Just Compensation” Means in a Tax Sale
The Supreme Court just decided Pung v. Isabella County. The case resolves a question left open by Tyler v. Hennepin County (2023): when the government forecloses on and sells property to satisfy a tax debt, is “just compensation” under the Takings Clause measured by the tax-sale auction price or by fair market value? Writing for…
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California Billionaire Tax Qualifies for November Ballot
Paul Jones, “California Billionaire Tax Qualifies for November Ballot” (Tax Notes, June 22, 2026): The California ballot initiative proposing a one-time billionaire wealth tax has qualified for the November ballot. But the success for proponents comes as some labor groups and traditionally progressive groups have now joined business interests and antitax groups in opposition to…
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King Charles to Reveal Personal Taxes
Sean Coughlan, “King Charles to reveal personal tax bill for first time as monarch” (BBC, June 21): King Charles will become Britain’s first monarch in modern times to reveal his personal tax bill. His tax payments will be shared on Thursday as a new element in the annual royal financial accounts, with the decision said…
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Florida Voters Will Decide Fate of Property Tax Relief Plan
Billy Hamilton (Tax Analysts): Florida Voters Will Decide Fate of Property Tax Relief Plan What makes this chain of events particularly interesting is that it combines three important trends in state and local tax policy and politics into a single issue. The first is the legislative desire, particularly in red states, to continue reducing taxes…
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WSJ: Rich Californians Are Finding Creative Ways to Get Ahead of the Billionaire Tax
Juliet Chung (WSJ): Rich Californians Are Finding Creative Ways to Get Ahead of the Billionaire Tax With help from their phalanx of tax and trust-and-estate advisers, California’s ultrawealthy are getting creative in the face of the proposed billionaire tax. If it becomes law, it would tax the net worth of billionaires who resided in California…
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Bloomberg: Coca-Cola, IRS Face Off in Tax Appeal With Huge Stakes for Both
Michael Rapoport & David Schultz (Bloomberg Law): Coca-Cola, IRS Face Off in Tax Appeal With Huge Stakes for Both The beverage giant and the government will square off in oral arguments [on June 25] before the US Court of Appeals for the Eleventh Circuit in Miami. Coca-Cola is appealing US Tax Court rulings that side…
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Jim Gadwood, Vice Chair of Miller & Chevalier’s Tax Department, May Be Next IRS Chief Counsel
Bloomberg Law, Tax Controversy Lawyer Is in Line for Top Counsel Job at IRS: Private-sector lawyer Jim Gadwood is being vetted to become IRS Chief Counsel, according to a person familiar with the process. If confirmed, he would be the fourth person in the role since President Donald Trump took office. … Gadwood, now vice…
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Congressional Tax Agenda Stalls as Trump Continues to Use Administrative Levers
As midterms approach, the timeline for tax legislation in this Congress becomes more compressed. This week brought bad news for two of the most plausible tax packages currently in play—and lower odds of major substantive tax action in 2026. The striking point is that distinct pressures are stalling legislative action on both a partisan and…
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Bloomberg Tax: Colombia Seeks Shield for Multinationals From Global Minimum Tax
Somesh Jha & Saim Saeed, Colombia Seeks Shield for Multinationals From Global Minimum Tax, Daily Tax Report (June 19, 2026): [Columbia] has submitted a formal request for a [Pillar 2] carve-out [under the UPE safe harbor] to the Organization for Economic Cooperation and Development . . . . The safe harbor would allow the top-up…
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WSJ: Being Generous to Your Kids? Don’t Stick Them With a Surprise Tax Bill
Laura Saunders, Being Generous to Your Kids? Don’t Stick Them With a Surprise Tax Bill (Wall Street Journal, June 19, 2026) Are you feeling generous toward your children or grandchildren? Before opening your wallet, check whether your largess could yield a surprise tax bill for them. The reason is the “kiddie tax,” an often-overlooked levy…
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WSJ: Rhode Island Joins the Tax Race to the Top
Wall Street Journal Editorial Board, Rhode Island Joins the Tax Race to the Top (June 15, 2026) Rhode Island Gov. Dan McKee’s five-year record has made him vulnerable to a primary challenge as he seeks re-election this year. Now he’s further punishing his state by signing a millionaire’s tax to win the support of government unions.…
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NY Times: Union Behind California Billionaire Tax Offers to Reduce the Rate
Laurel Rosenhall, Union Behind California Billionaire Tax Offers to Reduce the Rate (New York Times, June 18, 2026) With just days left to negotiate over a ballot proposition that would ask California voters to impose a one-time tax on billionaires, the union behind the measure is trying to strike a deal. It sent Gov. Gavin…
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Bloomberg: Varian Owes $7 Million After Tax Court Sunk Dividend Deductions
James Matheson (Bloomberg): Varian Owes $7 Million After Tax Court Sunk Dividend Deductions: Global medical manufacturer Varian Medical Systems Inc. is liable for a $7.3 million tax deficiency after a prior US Tax Court opinion disallowed some of the dividend deductions the company claimed for its 2018 tax year, according to a stipulated decision entered in the…
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WSJ: Jalen Brunson’s Tax Wisdom
Wall Street Journal, Editorial Board, Jalen Brunson’s Tax Wisdom: Jalen Brunson is the toast of New York after the 6-foot-2 point guard personally willed the New York Knicks to the NBA title on Saturday with a 45-point performance. The rest of his team scored 49. But it appears there’s another reason for New Yorkers to like the basketball…
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released two new reports concerning (1) amendments to section 4968 and (2) selected issues under section 108(e)(6):
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TaxProf Blog Op-Ed: Avi-Yonah on “When Is a Fee a Tax?”
This TaxProf Op-Ed on the recent decision in California v. Mullin is by Reuven S. Avi-Yonah (Michigan): When Is a Fee a Tax? Reuven S. Avi-Yonah On June 8, 2026, US District Judge Leo T. Sorokin (D. Mass.) issued an opinion invalidating the $100,000 payment that the Trump administration had imposed on applications to obtain…