Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax Policy in the Trump Administration
-
The Tax Stakes of Trump’s Executive Order on Marijuana
After almost a year of stalled action, the Trump Administration is continuing, by Executive Order, the Biden Administration’s efforts to reclassify marijuana from a Schedule I drug to a Schedule III drug. Should regulations finalize this change (and there almost certainly will be bipartisan opposition), effective federal tax rates on income from state-legal marijuana businesses…
-
Tariff Rollbacks, Protectionism, and Trump’s Political Coalition
Tariffs and trade protectionism go hand-in-hand—especially when those tariffs are not uniform. Through this lens, every rate transition—and there have been many since January—reshuffles the domestic economy’s winners and losers. This reshuffling has industry and interest group effects, as well as broader rhetorical and pocketbook implications for consumers. And all of these actors are potential…
-
NYT: “Big Businesses Are Cashing In on Trump’s Tax Cuts”
Andrew Duehren, Big Businesses Are Cashing In on Trump’s Tax Cuts, N.Y. Times (Dec. 12, 2025): In the months since the passage [of the 2025 budget bill] in July, corporations like Walmart, Amazon, Verizon and Eli Lilly have all disclosed in securities filings that the law would reduce their cash tax payments in the near…
-
Politico: “Trump Administration Races to Finalize Tariff Payments — and Hamstring Possible Refunds”
Ari Hawkins & Doug Palmer, Trump Administration Races to Finalize Tariff Payments — and Hamstring Possible Refunds, Politico (Dec. 14, 2025): The Trump administration is racing to deposit the money it’s raised from tariffs into the U.S. Treasury, a tactic that could make it harder for companies to get refunds for duties the Supreme Court…
-
Tariff Non-Uniformity from the Left and Right
The current era of tariffs has unsettled the turn-of-the-century political consensus around free trade. What’s sometimes lost in this reshuffling is the texture of tariffs as currently imposed. In the current policy environment, this texture differs from the myriad exemptions and ratings under VATs or sales taxes. Tariff schedules tend to be significantly more granular…
-
Non-Tax Perspectives on the Tariff Cases
As manufacturer’s orders slow and tariff refund suits proliferate in anticipation of the Supreme Court’s pending decision in Learrning Resources, it’s worth stepping back from pragmatics and taking in recent commentary on the decision’s implications for the Supreme Court’s jurisprudence, the United States’ foreign policy, and the Executive Branch’s ability to control the domestic economy.…
-
NY Times: Ahead of Tariff Ruling, Businesses Race to Secure Refunds
Tony Romm & Ana Swanson, Ahead of Tariff Ruling, Businesses Race to Secure Refunds, N.Y. Times (Dec. 3, 2025): From the buy-in-bulk retailer Costco to the canned-tuna company Bumble Bee Foods, some businesses are racing to get in line for tariff refunds, anticipating that the Supreme Court will soon rule against President Trump and force…
-
Giving Tuesday 2025: Transitions and Tax Incentives
How will the One Big Beautiful Bill Act affect year-end charitable giving in 2025? While some donors have incentives to accelerate donations into the current taxable year, other donors benefit by deferring contributions to 2026. It’s time for taxpayers to build their Excel models and call their investment advisors. Details follow.
-
For a Limited Time Only?: Transition Guidance for No Tax on Tips
The One Big Beautiful Bill Act created new tax exemptions for qualified tips and qualified overtime pay, both of which take effect for 2025. There’s been a lot of administrative guidance on these provisions since July, it’s not a surprise that implementing these individual tax benefits has proven challenging—and may create significant confusion for individual…
-
Herzfeld: Rationalizing the Post-OBBBA International Tax Rules, Part 2
Mindy Herzfeld (Florida), Rationalizing the Post-OBBBA International Tax Rules, Part 2, 120 Tax Notes Int’l 1416 (Dec. 1, 2025) The second Trump administration’s regulatory priorities for Treasury are twofold: implementation of the One Big Beautiful Bill Act (P.L. 119-21) and deregulation. The 2025-2026 priority guidance plan issued on September 30 — significantly pared down from prior years’ plans — highlights the shift…
-
Narotzki: Predicting Tariff Decisions from Oral Argument Transcripts with AI Models
Doron Narotzki (Akron) has a new working paper on SSRN, Predicting Tariff Decisions from Oral Argument Transcripts with AI Models. Here is the abstract:
-
Hellerstein & Appleby: A State Tax Perspective on Proposed Federal Cryptoasset Guidance
Walter Hellerstein (Georgia) & Andrew Appleby (Tennessee), A State Tax Perspective on Proposed Federal Cryptoasset Guidance, 189 Tax Notes Fed. 1285 (Nov. 24, 2025). In this article, Hellerstein and Appleby consider the state tax implications of proposed federal income tax guidance on the treatment of cryptoassets.
-
ICE and the IRS: Preliminary Injunction and Other Updates
On Friday, November 21, Judge Colleen Kollar-Kotelly issued a preliminary injunction barring the IRS from sharing certain taxpayer data with the Department of Homeland Security, stayed an April information-sharing agreement between the IRS and Immigrations and Customs Enforcement, and ordered the IRS to inform the District Court for D.C. before making further disclosures of taxpayer…
-
Tax Foundation: Fact Checking the Trump Administration
Americans are asking: When will people see lower taxes from the OBBBA, and how big will those spring refund checks be? And what’s the story with those $2,000 tariff refund checks? The Tax Foundation has some fact-checking on both points, with related commentary below the fold.
-
NY Times: The I.R.S. Tried to Stop This Tax Dodge. Scott Bessent Used It Anyway.
Andrew Duehren, The I.R.S. Tried to Stop This Tax Dodge. Scott Bessent Used It Anyway., N.Y. Times (Nov. 12, 2025) (quoting Walter D. Schwidetzky): It was an easy and, by all accounts, legal way to avoid paying thousands, and potentially millions, in federal taxes. Just set up an investment firm with the right legal structure,…
-
NYT & WSJ: Two Views on CAMT after the OBBBA
Two stories in flagship newspapers. Same topics, same day. Very different conclusions. In alphabetical order by author’s last name:
-
Clarke & Glogower: Tariffs and the Taxing Power: Historical Lessons for Major Questions and Nondelegation
Conor Clarke (Wash U) & Ari Glogower (Northwestern), Tariffs and the Taxing Power: Historical Lessons for Major Questions and Nondelegation, 103 Wash. U. L. Rev. __ (forthcoming 2026):
-
WSJ: “Trump’s Tax Cuts Are Exposing Companies to Biden’s Tax Hike”
Wall Street Journal: Trump’s Tax Cuts Are Exposing Companies to Biden’s Tax Hike: Democrats’ older alternative minimum tax claws back billions of dollars in savings from newer GOP law.
-
Penn Wharton Budget Model: OBBBA International Tax Reforms
Penn Wharton released updated cost estimates for the OBBBA International Tax Reforms: Summary: We project that corporate tax revenue will decrease by $276 billion over 10 years on a conventional basis due to changes in international tax provisions related to the Section 250 deduction under OBBBA.
-
NY Times: Will Trump’s Tariffs Survive Supreme Court’s ‘Major Questions’ Test?
Adam Liptak, Will Trump’s Tariffs Survive Supreme Court’s ‘Major Questions’ Test?, N.Y. Times (Oct. 27, 2025): The Supreme Court used the “major questions doctrine” to reject much of the Biden administration’s agenda, including its efforts to address climate change, the Covid-19 pandemic and student debt. The court’s commitment to the doctrine will be tested next week when it hears arguments…
-
Senators Question Legality of IRS CEO Position
Tax Notes, Senators Question Legality of IRS CEO Position: Three Senate Democrats are asking Treasury Secretary Scott Bessent to explain the legal basis behind appointing Social Security Administration Commissioner Frank Bisignano as CEO of the tax collection agency.
-
The Trump Tariffs and the Early History of the Taxing Power
As Sloan noted a few days ago, Friday was the final deadline for amicus briefs in the Trump tariff cases. I filed one of those briefs (in support of the companies challenging the Trump tariffs), alongside Jon Endean (Brooklyn), Ari Glogower (Northwestern), and Daniel Hemel (NYU). (The brief was also supported by the indefatigable students…
-
WSJ Op-Ed and Letters: Business Tax Reform and Tariffs
In a Wall Street Journal op-ed, AEI fellows Paul Ryan and Kyle Pomerleau revive House Republicans’ 2016 proposal for a destination-based cash flow tax (DBCFT) as an alternative to tariffs and a way to “finish the job” on tax reform initated by the Tax Cuts and Jobs Act—”the ultimate made-in-America policy.” Letters from Adam Michel…
-
Law Prof Amicus Briefs in the Tariff Cases
In Learning Resources, Inc. v. Trump, No. 24-1287 (Sup. Ct.) and Trump v. V.O.S. Selections, Inc., No. 25-250 (Sup. Ct.), the Supreme Court is considering the Trump Administration’s authority to impose tariffs under the International Emergency Economic Powers Act (IEEPA). Oral arguments are Wednesday, November 5, at 10 a.m. Eastern. Law school faculty and affiliates…
-
Tax Policy In The Trump Administration
Bloomberg, IRS Chief’s Gaffes, Sudden Exit Roil the Fractured Tax Agency Bloomberg, IRS Vets and Wild Cards: Trump’s Options for Replacing Long Bloomberg, NY, NJ Fail in Court Bid to Keep Their SALT Cap Workarounds Bloomberg, Trump Tax Law Squeezes Poor, Boosts Income for Wealthy, CBO Says Law360, Midyear Review: A Look At The Tax…