Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Policy in the Trump Administration
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A Retro Tax Reconstruction of Trump’s $5,000 Dividend
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…
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SALT Break Sought by New York, California Pays Off Across the US
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…
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Politico: Trump Calls for Hollywood Tax Incentive
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…
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N.Y. Times: Audit Revenue Has Plummeted Under Trump, Watchdog Finds
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…
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Tariff Litigation Update
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…
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IRS Guidance on Race and Admissions in Colleges (and Law Schools) Passes White House Review
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…
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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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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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Mother Jones: The IRS Is Imploding
In Mother Jones, Stephanie Mencimer writes about the current state of the IRS in “The IRS Is Imploding.” From the piece: These aren’t just anecdotal one-offs. A June report to Congress from the Taxpayer Advocate Service, an independent agency within the IRS, found that live humans answered 20 percent fewer calls during this year’s tax filing season…
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Commentary on Section 301 Tariffs
Tariffs are in the news again. From Politico, Oliver Ward, Megan Messerly, and Daniel Desrochers report: The Trump administration on Thursday finalized new double-digit tariffs on dozens of U.S. trading partners as it seeks to reconstitute sweeping duties struck down by the Supreme Court in February. The new duties, which range from 10 to 12.5…
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Commentary on Section 338 Tariffs
In “Trump to Impose 50% Tariff on Many Canadian Goods,” Ana Swanson and Ian Austen report for the New York Times: President Trump on Monday signed orders to impose a 50 percent tariff on a wide range of Canadian goods, claiming that Canada had discriminated against the United States in key industries. The tariffs, which…
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N.Y. Times: Judge Denounces Trump’s I.R.S. Suit as Improper Exercise in Self-Dealing
For the New York Times, Andrew Duehren and Alan Feuer have a piece, “N.Y. Times: Judge Denounces Trump’s I.R.S. Suit as Improper Exercise in Self-Dealing.” From the piece: A federal judge ruled on Monday that President Trump’s lawsuit against the Internal Revenue Service was an improper exercise in self-dealing and barred him from claiming that…
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Treasury’s Top Tax Official to Depart
Erin Slowey and Erin Schilling, “Top Treasury Tax Official, Acting IRS Lawyer Kies to Depart” (Bloomberg, July 13): Ken Kies, the top Treasury tax policy official who also oversees the IRS legal arm, is departing his dual roles, an administration official said Monday. The Senate confirmed Kies as the assistant secretary for tax policy at…
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The OBBBA’s Trump Accounts Open on July 4
On the OBBBA’s first anniversary, one of the law’s more unusual experiments takes full effect. Starting July 4, 2026, contributions may be made to minor children’s 530A accounts—better known as Trump Accounts. There’s fanfare: next week, the NYSE and Nasdaq opening bells will ring from the Oval Office to celebrate families’ ability to fund these…
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ABA: Public Service Loan Forgiveness Ruling Is a Win for Access to Justice
American Bar Association, Public Service Loan Forgiveness Ruling Is a Win for Access to Justice (July 2, 2026): Court rulings that this week struck down the U.S. Department of Education’s new Public Service Loan Forgiveness (PSLF) employer rule are a victory for the rule of law and for everyone working to promote access to justice…
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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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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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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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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…
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Somin: H-1B Visa Fee Ruling Extends Learning Resources Beyond Tariffs
Jon Endean previously covered Judge Leo T. Sorokin’s decision (D. Mass.) holding that the Trump Administration’s $100,000 H-1B visa fee is a tax that exceeds the authority Congress delegated to the Executive Branch. The Supreme Court’s decision invalidating the Trump Administration’s IEEPA tariffs in Learning Resources figured prominently in Sorokin’s decision. The government is expected…
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$100,000 H-1B Visa Fee Ruled Unlawful
In a challenge brought by twenty states challenging President Trump’s $100,000 fee imposed on employers seeking new H-1B visas, Judge Leo T. Sorokin (D. Mass.) ruled in favor of the plaintiffs, vacating the associated policy. From the opinion: The Court begins with Plaintiffs’ assertion that the Policy intrudes upon Congress’s taxing power. The first inquiry…
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Sarin (NY Times): No Wonder Everyone’s Rallying Around This Terrible Idea
In the New York Times, Natasha Sarin (Yale), a contributing Opinion writer, has a new piece, “No Wonder Everyone’s Rallying Around This Terrible Idea.” From the piece: In a nation seemingly unable to agree on anything, people appear to be converging on one idea: Taxes are bad. In addition to the calls for broad-based middle-class…
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NY Times: Inside the Deal to Drop Trump’s $10 Billion Suit Against the I.R.S.
For the New York Times, Alan Feuer, Andrew Duehren, Glenn Thrush, Ben Protess, and Maggie Haberman have a story, “Inside the Deal to Drop Trump’s $10 Billion Suit Against the I.R.S.” From the piece: President Trump had sued the I.R.S. for $10 billion, and a federal judge was pressing the Justice Department to explain how…