Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Policy in the Trump Administration
-
TaxProf Op-Ed: Narotzki on Learning Resources and the Limits of Emergency Tariffs
This TaxProf Blog Op-Ed on Learning Resources is by Doron Narotzki (Akron; Google Scholar): Learning Resources and the Limits of Emergency Tariffs Doron Narotzki The Supreme Court’s decision in Learning Resources, Inc. v. Trump[1] is best understood not as a trade case, but as a power-of-the-purse case. The Court held that the International Emergency Economic…
-
TaxProf Op-Ed: Saito on Major Questions, Learning Resources, and the End of Tax Regulation
This TaxProf Op-Ed on Learning Resources is by Blaine Saito (Ohio State; Google Scholar): Major Questions, Learning Resources, and the End of Tax Regulation Blaine Saito The Supreme Court’s decision in Learning Resources, Inc. v. United States[1] did more than just strike down a set of emergency tariffs. It effectively doubled down on the Major Questions Doctrine (MQD) without helping…
-
The Conversation: Non-U.S. Perspectives on Learning Resources and the Future of Tariffs
The Conversation has commentary from faculty outside of law schools on the Supreme Court’s decision in Learning Resources that struck down the Trump Administration’s IEEPA tariffs. Five post-decision articles for a popular audience, including four perspectives from non-U.S. scholars, below the fold.
-
TaxProf Op-Ed: Morse, Oei & Ring on Learning Resources as a Statutory Interpretation Decision
This TaxProf Op-Ed on Learning Resources is by Susan C. Morse (Texas; Google Scholar), Shu-Yi Oei (Duke; Google Scholar) & Diane M. Ring (Boston College; Google Scholar): Learning Resources Is a Statutory Interpretation Decision—And That’s a Good Thing Susan C. Morse, Shu-Yi Oei & Diane M. Ring Learning Resources, Inc. v. Trump, the Supreme Court case that struck…
-
TaxProf Op-Ed: Appleby on the State Tax Implications of Learning Resources
This TaxProf Op-Ed on Learning Resources is by Andrew Appleby (Tennessee; SSRN): A State Tax Perspective on Learning Resources Andrew Appleby Although Learning Resources raises foundational questions about the delegation of power that resonate across state and local taxation, the decision’s most immediate state tax consequence centers on whether buyers can recover sales taxes paid on the…
-
NY Times: Why the I.R.S. Wants $15 Billion From Meta
From Jesse Drucker, Alexandra Ostasiewicz, June Kim, and Joey Sendaydiego, the New York Times produced a video explaining dispute between Meta (the holding company of Facebook) and the IRS that is currently pending in the Tax Court. At issue is a notice of deficiency from the IRS of just under $16 billion (before interest and…
-
TaxProf Op-Ed: Endean on Delegations of the Taxing Power
This TaxProf Op-Ed on Learning Resources is by Jon Endean (Brooklyn Law School; SSRN): Delegations of the Taxing Power Jon Endean The Court’s decision in Learning Resources, Inc. v. Trump is undoubtedly one of the most consequential of the term, firmly rejecting the President’s position that IEEPA delegates the power to impose tariffs to the President. According to the Court’s opinion, “Our…
-
TaxProf Op-Ed: Avi-Yonah on Learning Resources and Regulatory Taxation
This TaxProf Op-Ed on Learning Resources is by Reuven S. Avi-Yonah (Google Scholar), Irwin I. Cohn Professor of Law at the University of Michigan: Learning Resources and Regulatory Taxation Reuven S. Avi-Yonah On February 20, 2026, the Supreme Court issued its opinion in Learning Resources, Inc. v. Trump.[1] The Court held by a 6-3 majority…
-
The Supreme Court Strikes Down Trump’s IEEPA Tariffs
Friday wasn’t an easy day for the Trump Administration. GDP growth missed expectations badly, President Trump acknowledged the possibility of a military strike on Iran, and the President’s approval ratings hit a second-term low. And, the Supreme Court struck down the Trump Administration’s tariffs under the International Emergency Economic Powers Act (IEEPA). The Court’s 6-3…
-
ICE and the IRS: Inadvertent Disclosures Edition
In court filings on February 11, 2026, the IRS revealed additional details about its response to a June 2025 ICE request for 1.3 million taxpayers’ last known addresses—data that the Code expressly protects as part of “taxpayer identity.” Under the terms of an April 2025 information-sharing agreement, the IRS provided this information to ICE for…
-
Mitch Daniels: A Consumption Tax on Americans is Brewing. Tariffs Are the Dry Run.
Echoing the famous quip by Larry Summers explaining the lack of a national VAT in the United States on the grounds that “Liberals think it’s regressive and conservatives think it’s a money machine”—but if liberals and conservatives reverse their positions, a VAT might be implemented in the United States—Mitch Daniels, the former Republican governor of…
-
NY Times: States Say No Thanks to Trump Tax Cuts, Drawing Republican Fire
Andrew Duehren, “States Say No Thanks to Trump Tax Cuts, Drawing Republican Fire,” N.Y. Times (Feb. 14, 2026):
-
Tax Notes: Doughnut Hole or a Different Kind of Pastry? Tariffs, Taxes, and Regulation
Glenn C. McCoy, Jr. & Jonathan Geiger, Doughnut Hole or a Different Kind of Pastry? Tariffs, Taxes, and Regulation, 119 Tax Notes St. 451 (Feb. 9, 2026):
-
White House Report Examines State Income Tax Elimination
Tax Notes: White House Report Examines State Income Tax Elimination A report from the White House touts the benefits of states eliminating their income taxes in favor of a broader sales tax, but one group contends that the report’s figures don’t hold up to scrutiny. The 18-page report from the White House’s Council of Economic Advisers, issued…
-
Avi-Yonah, Farrell & Imparato: Can the EU’s Foreign Subsidy Regulation ‘Discipline’ U.S. Subsidies?
Reuven S. Avi-Yonah (Michigan), Jennifer Farrell (Western University) & Domenico Imparato (Berkeley), Can the EU’s Foreign Subsidy Regulation ‘Discipline’ U.S. Subsidies?, 121 Tax Notes Int’l 837 (Feb. 2, 2026):
-
WHCEA: The Economic Impact of State Income Tax Elimination
The White House Council of Economic Advisers has published a new report titled, The Economic Impact of State Income Tax Elimination. From the report’s executive summary: For years, no-income-tax states like Texas, Tennessee, and Florida have often led the pack in attracting and retaining residents looking to put down roots where they do not have…
-
A Pause on Student Loan Collections for a Record Refund Season
Filing season has begun, and it promises to be a humdinger. The OBBBA’s July 2025 tax cut should send refunds soaring, as taxpayers reconcile their final liability against withholdings that largely reflect pre-change law. Savvy planners may have even lower final tax bills—and even bigger refunds—if they leveraged the OBBBA’s transition timelines to their advantage.…
-
Bloomberg Tax: Global Tax Deal Sparks Fear US Law Will Be Tougher to Change
Treasury expressly framed January’s side-by-side package as “recogniz[ing] the tax sovereignty of the United States over the worldwide operations of U.S. companies.” Although Pillar Two may have survived, the side-by-side package complicates the OECD’s multilateral framework and may give the United States a competitive advantage. But what if the side-by-side package actually constrains U.S. sovereignty,…
-
IRS Enforcement Leadership Changes
Bloomberg Law: IRS Leader Shake-Up Bleeds Criminal, Civil Enforcement Oversight The line between tax auditors policing mere civil infractions versus serious tax crimes is blurring in the latest reorganization at the top of the IRS. Jarod Koopman, a longtime and respected criminal investigator, took over the top job for compliance at the IRS in October. Under the…
-
Galle et al.: Expert Report on Valuation of Controlling Shares of Publicly Traded Companies Under the California Billionaire Tax Act
Brian Galle (UC Berkeley), David Gamage (University of Missouri), Emmanuel Saez (UC Berkeley), and Darien Shanske (UC Davis) have produced a memo attempting to address concerns over the proposed California Billionaire Tax Act:
-
White House Proposal to allow 401(k) Withdrawals for Home Purchases
Brett Samuels (Bloomberg Law): Trump’s 401(k) Home Buyer Idea Requires Retirement Rule Shifts A forthcoming White House proposal would allow use of 401(k)s for down payments on home purchases, meaning shifts in long-held regulations on plan withdrawals, and possibly new legislation.
-
States Continue to Decouple From OBBBA
Michael J. Bologna (Bloomberg Law): More States Expected to Decouple From Trump’s Tax-Cutting Agenda Lawmakers in Delaware, Illinois, Michigan, Pennsylvania, and Rhode Island took on a task that most states ignored last year: passing legislation to separate from the tax-cutting features of President Donald Trump’s signature 2025 law. Now governors and legislators in nearly two…
-
Romney (NYT): Tax the Rich, Like Me
Mitt Romney, Opinion, “Tax the Rich, Like Me,” N.Y. Times (Dec. 19, 2025): Typically, Democrats insist on higher taxes, and Republicans insist on lower spending. But given the magnitude of our national debt as well as the proximity of the cliff, both are necessary.
-
SCOTUSBlog: How the Tariffs Could Be Refunded if the Court Sides Against Trump
Amy Howe, “How the Tariffs Could Be Refunded if the Court Sides Against Trump,” SCOTUSBlog (Dec. 18, 2025): It has been slightly over six weeks since the Supreme Court heard oral arguments in the challenge to President Donald Trump’s power to impose sweeping tariffs in a series of executive orders earlier this year. During the…
-
Trump Order Renews Hope for Cannabis Tax Relief
Tax Analysts: “President Trump has signed an executive order intended to expedite the marijuana rescheduling effort, bringing cannabis businesses ever closer to being able to deduct their expenses.”