Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Policy in the Trump Administration
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New York Times: Trump Clears Way for Corporate Tax Dodge Hidden in the Fine Print
Jesse Drucker & Dyland Freedman, Trump Clears Way for Corporate Tax Dodge Hidden in the Fine Print (New York Times, May 29, 2026) A year ago, the Trump administration withdrew from a global effort to curb offshore tax-dodging by multinational companies. That decision has been a huge gift to corporate America, enabling companies to avoid…
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Bloomberg: “Democrats’ 100% Tax Plan on Fund Payouts Zeroes In on GOP Angst”
Chris Cioffi (Bloomberg Law): Democrats’ 100% Tax Plan on Fund Payouts Zeroes In on GOP Angst Democrats are trying to force the GOP’s hand by introducing a 100% tax on payments from the Justice Department’s new fund for victims of government weaponization, even as Republicans face increasing pressure on what’s become a politically toxic $1.8 billion…
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Costco Fights Tariff Refund Class Action Suit
Natalie Olivo (Bloomberg Law): Costco Calls Suit Over Tariff Refunds Premature Costco urged an Illinois federal court to toss a putative consumer class action seeking to recoup the higher costs that shoppers paid under President Donald Trump’s global tariffs, contending that the case is premature in the wake of uncertain corporate refunds.
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Trump’s Surgeon General Pick Also Is a Farmer for Tax Purposes
Daniel Han, Nicole Saphier Is Trump’s Pick for Surgeon General. She’s Also a ‘Farmer’ in New Jersey—and Gets a Tax Break, Politico (May 21, 2026):
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Trump v. IRS Dismissed
In Tax Notes, Mary Katherine Browne reports as follows: President Trump has dropped his lawsuit against the IRS in exchange for a $1.8 billion compensation fund established by the Justice Department for individuals who allege they were targeted by the Biden administration. In a May 18 filing, Trump gave notice to the U.S. District Court…
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Details of New IRS Conservation Easement Settlement Offer
Kristen Parillo (Tax Analysts): New IRS Easement Settlement Offer Eliminates Up-Front Payment Eligible partnerships that accept the terms of the IRS’s latest — and purportedly final — settlement offer for syndicated conservation easement and historic preservation easement cases won’t be required to pay the full settlement amount up front. The liability will instead be subject to…
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Section 122 Tariffs Ruled Unlawful
In a previous post, I previewed the consolidated cases, Burlap and Barrel, Inc. v. Trump and Oregon v. Trump, in which a set of private plaintiffs and state plaintiffs sued the Trump administration over its invocation of section 122 in rolling out 10% baseline tariffs on (nearly) all imports into the United States following the administration’s loss in Learning Resources.…
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NY Times: Justice Dept. Officials Consider Settling Trump Suit Against I.R.S.
In the New York Times, Andrew Duehren and Alan Feuer report as follows: The Justice Department is holding internal discussions about settling President Trump’s lawsuit against the Internal Revenue Service in the coming days, according to three people familiar with the deliberations, a move that could involve the government directly providing taxpayer funds or another…
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Updates on Efforts to Improve Nonprofit Transparency
Two related items on administrative efforts to improve disclosure by nonprofits. One involves proposed regulations and planned revisions to Form 990; the other, litigation over the First Amendment viability of statutory requirements to disclose donors. Links and excerpts, below the fold.
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NTA 56th Annual Spring Symposium
The National Tax Association 56th Annual Spring Symposium is being held in Washington DC yesterday and today (May 7-8, 2026). Program is available here (and also below). Thursday, May 7, 2026 Time Function 8:50 – 9:00 AM Welcome 9:00 – 10:15 AM The One Big Beautiful Bill: Impacts & Implications (Panel Session)Moderator:Andy Duehren, New York…
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Amici Appointed in Trump v. IRS
In Tax Notes, Mary Katherine Browne reports as follows: Six private practice attorneys have been asked to weigh in on whether subject matter jurisdiction exists in a $10 billion lawsuit that would allow a court to adjudicate the president’s case against his own government. In an April 29 order, Judge Kathleen M. Williams of the…
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NYT: Are Democrats Becoming a Party of Tax Cuts?
Writing for The New York Times in a piece titled “Are Democrats Becoming a Party of Tax Cuts?“, Andrew Duehren reports the following: Typically, a bill like the one Senator Chris Van Hollen, a Maryland Democrat, introduced last month would not make much of a splash. * * * The bill was the subject of…
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Reconciliation 2.0, Meet the Smaller IRS
Two tax stories collided in Washington this week. House Speaker Mike Johnson set a “skinny” scope for Reconciliation 2.0, the potential partisan legislative package that would help end what’s now the longest government shutdown in U.S. history.* And, on Tax Day, Senators grilled IRS CEO Frank Bisignano about the Trump Administration’s proposed $1.4 billion cut…
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NYT: Inside Trump’s Supercharged Tax Season
New York Times: ‘I Got Back Every Penny’: Inside Trump’s Supercharged Tax Season The law Republicans passed last year has so far been largely imperceptible to most Americans. That’s changing as tens of millions file their taxes this spring.
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The Promise and Peril of the OBBBA’s Populist Tax Breaks
With less than two weeks before Tax Day, Treasury Secretary Scott Bessent has touted the uptake of the One Big Beautiful Bill Act’s big four tax breaks for individuals: “no tax on tips,” “no tax on overtime,” “no tax on car loan interest,” and the additional deduction for seniors (which really isn’t “no tax on…
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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…
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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…
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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…
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Tax Law Center: Webinar on Clean Energy Credits
On Monday, March 30, 2026, NYU’s Tax Law Center is hosting a webinar on the prohibited foreign entity (PFE) rules applicable to clean energy credits. Details below the fold.
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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…
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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…
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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…
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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…
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Rubin: The Tax Nerd Who Bet His Life Savings Against DOGE
Richard Rubin reports on a young economist who staked his “life savings”—$342,195.63—on federal spending increasing during the first year of the Trump Administration, compared to the final quarter of the Biden Administration. And he won. More on the intersection of prediction markets, herd wisdom, and mandatory spending—plus the economist’s winnings—below the fold.
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Senators Cruz & Scott Ask for Capital Gains to be Indexed to Inflation
According to reporting in Tax Notes, Bloomberg Law, and others, Senators Ted Cruz (R-TX) and Tim Scott (R-SC) have written a letter to Treasury Secretary Scott Bessent (who, at least for a few more days, is also the acting commissioner of the IRS) advocating for the Trump administration to index capital gains to inflation by…