Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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AI Tokens and Sales Tax: Key Considerations
Stephen P. Kranz, Mark E. Nebergall & Jonathan C. Hague (McDermott Will & Schulte), AI Tokens and Sales Tax: Key Considerations, 121 Tax Notes State 239 (July 27, 2026): AI product providers increasingly offer customers access to their platforms through “tokens,” credits, or other usage-based entitlements. These arrangements may allow a customer to submit prompts, process…
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Libby: Theories of University Endowment Taxation
Lauren Libby (Ph.D. Candidate, Yale), Theories of University Endowment Taxation, 103 Wash. U. L. Rev. 991 (2026) (reviewed by Mirit Eyal (Alabama) here) University endowment taxation is now one of the most significant issues in U.S. federal tax policy, and it only promises to grow in prominence over the next four years. Yet while growing…
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Choi & Connell: AI Deceleration (or Acceleration) by Taxation
Jonathan H. Choi (Washington University) & Paul Connell (Wisconsin), AI Deceleration (or Acceleration) by Taxation: Even the chief executives of America’s leading AI companies cannot agree on whether their products will substitute for or complement human labor. Yet most policy proposals, from data center bans to bonus depreciation for AI hardware, commit policymakers ex ante to just…
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Fraser: An Annotated California Billionaire Tax Act
Erin Fraser, a former student, has created an annotated version of California’s proposed 2026 Billionaire Tax Act, one of two major “tax-the-rich” measures that are on the ballot for 14% of Americans this November. Fraser’s accessible website—with cross-references, drafters’ comments, and clearly identified AI summaries, among other features—is a marked upgrade over the State of…
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The NextGen UBE Launches Next Week
The first NextGen Uniform Bar Examination will be administered on July 28–29, 2026 in ten jurisdictions. Best wishes to those law graduates sitting for the new exam, both for their final preparation and in the inaugural administration! Although the redesigned exam is 25% shorter than the legacy UBE, the focus appears to be more demanding:…
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Costinot & Werning: Should We Tax Trade? A Pigouvian Perspective
Arnaud Costinot (MIT) & Iván Werning (MIT), Should We Tax Trade? A Pigouvian Perspective, NBER Working Paper No. 35461 (July 2026):
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Treasury Raises Concerns About Tax-Aware Investment Products
At a Wall Street Tax Association seminar on July 21, 2026, Treasury officials discussed various strategies involving regulated investment companies in which Treasury has taken an interest. The next day, Treasury Secretary Scott Bessent posted on X about “too good to be true” investment strategies. Although Treasury did not announce formal guidance, the discussion generated…
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SSRN Review & Roundup: Harpaz Reviews Seto’s No More Tiers
This week, Assaf Harpaz (Georgia; Google Scholar) reviews a new work by Theodore P. Seto (Loyola LA; Google Scholar), No More Tiers: Rebuilding Auditability in Partnership Taxation. Over the past decades, large partnerships have grown increasingly complex, often featuring multiple layers of ownership structures with numerous tiers. Large partnerships are rarely audited, and when audits…
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CPAacademy: RACE, WEALTH, AND U.S. TAX POLICY: WHO BENEFITS FROM AND WHO BEARS TAX BURDENS?
CPAacademy, RACE, WEALTH, AND U.S. TAX POLICY: WHO BENEFITS FROM AND WHO BEARS TAX BURDENS?: For generations, tax policy has played a significant role in shaping economic opportunity, wealth accumulation, and financial security in America. This webinar examines how key features of the U.S. tax system—including preferential treatment for inherited wealth, gifts, and capital income—have…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 53 (July 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron:
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Bloomberg: Amgen Settles Investor Suit Over Tax Liability for $74 Million
Gillian R. Brassil (Bloomberg): Amgen Settles Investor Suit Over Tax Liability for $74 Million: Amgen Inc. agreed to cough up $74 million to resolve allegations that the pharmaceutical giant delayed alerting investors that it may owe the IRS $10.7 billion in back taxes and penalties. The proposed settlement class includes those who acquired Amgen stock…
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D.C. Circuit Affirms Sentence for Trump Tax Return Leaker
Mary Katherine Browne, “Appeals Court Affirms Sentence for Trump Tax Return Leaker” (Tax Notes, July 20, 2026): The D.C. Circuit rejected a former IRS contractor’s bid to overturn his five-year sentence for leaking the tax returns of President Trump and thousands of wealthy taxpayers, finding no evidence of a predetermined sentence or improper outside pressure.…
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Avi-Yonah: Taxation and Deglobalization
Reuven S. Avi-Yonah (Michigan) has a new piece posted to SSRN, “Taxation and Deglobalization.” Here’s the abstract: Since 2016, the world has been in the process of deglobalization, as evidenced by rising tariffs, limits on immigration, and the potential revival of exchange controls. The downsides of deglobalization are evident in an inflation surge, reduced economic…
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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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Christensen & Appleby: State Tax Exemptions for Tribal Cultural Property
Grant Christensen (Alabama) and Andrew Appleby (Tennessee) have a new piece recently published in the Yale Law Journal Forum, “State Tax Exemptions for Tribal Cultural Property.” Here’s the abstract: In 2026, the California legislature enacted Assembly Bill (AB) 1485, which exempts from real property transfer taxes certain transactions that return tribal land to tribes. This…
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Hasen: Taxing the Transfer of Compensatory Partnership Interests
David Hasen (Florida) has posted a new piece on SSRN, “Taxing the Transfer of Compensatory Partnership Interests.” Here’s the abstract: The proper rules for taxing the exchange of partnership interests for services have never been settled. This paper argues that background policy considerations support a regime that treats the receipt of most profits interests as…
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Gambling Loss Limitations Condemned at IRS Hearing
Trevor Sikes, “Gambling Loss Haircut Lambasted at IRS Hearing” (Tax Notes, July 20, 2026): The One Big Beautiful Bill Act’s 90 percent limitation on gambling loss deductions is grossly unfair to honest gamblers and should be repealed, according to stakeholders. Speakers took the opportunity at a July 17 IRS hearing on proposed regulations on gambling…
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Alstadsæter, Johannesen, Le Guern Herry & Zucman on Transparency and Offshore Wealth
Annette Alstadsæter, Niels Johannesen, Ségal Le Guern Herry & Gabriel Zucman, “Global Financial Transparency and Offshore Wealth Accumulation” (NBER Working Paper, July 2026): This paper uses administrative data to analyze wealth flows from Norway to offshore tax havens before and after a major improvement of global financial transparency: automatic exchange of bank account information between…
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Second Circuit Rejects Counties’ Suit Against NYC Congestion Toll
This Second Circuit decision is important both for how it navigated the Tax Injunction Act and for its “right to travel” analysis. Cameron Browne (Tax Analysts): Second Circuit Rejects Counties’ Suit Against NYC Congestion Toll Two New York counties failed to prove that New York City’s congestion pricing program was an unauthorized tax that violated…
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AI Won’t Shrink Corporate Tax Teams Much. Here’s Why.
Michael V. Sala, AI Won’t Shrink Corporate Tax Teams Much. Here’s Why., 121 Tax Notes State 189 (July 20, 2026) In this article, Sala argues that the anticipated effects of artificial intelligence agents in modern corporate tax functions are greatly overstated because AI ultimately cannot shoulder regulatory, ethical, or financial consequences of culpability.
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Herzfeld: Mocking Up the Digital Services Tax War Games
Mindy Herzfeld (Florida), Mocking Up the Digital Services Tax War Games, 192 Tax Notes Fed. 185 (July 13, 2026) In the warning, which was issued the day after the European Commission agreed to the terms of the EU-U.S. trade deal, he threatened to impose a 100 percent tariff on all goods from countries that implemented a…
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Pittsburgh Tax Review Symposium: AI in Tax Practice and Law School Education
The Pittsburgh Tax Review has published Symposium, AI in Tax Practice and Law School Education, 23 Pitt, Tax Rev. 283- 353 (2026) : Sarah B. Lawsky (Illinois), Direct File as Formalization, 23 Pitt. Tax Rev. 283 (2026) (reviewed by Jeff Gordon (Vanderbilt) here): Direct File was a program created by the United States government that…
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Saito: Granting Tax
Blaine G. Saito (Ohio State), Granting Tax, 63 Hous. L. Rev. 629 (2026): The U.S. federal tax system is failing to promote the values of democracy and egalitarianism. Powerful interests like the wealthy and multinational entities have bent the tax system to their whim. Meanwhile, disadvantaged groups and the working class have little voice or…
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SteuerLLM: An Open-Source AI Model for German Tax Law
An international team of researchers has released SteuerLLM, am open-source, 28-billion-parameter AI model trained on German tax law materials. In a companion article, the team reports that SteuerLLM outperforms general-purpose instruction-tuned models of comparable size and, in some tests, substantially larger systems. These results suggest that domain-specific design may matter more than parameter count for…
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Inside Higher Ed: The Risk Proposition of Law School Is Changing
Sari Kisilevsky, Inside Higher Ed, The Risk Proposition of Law School Is Changing (June 22, 2026): [Conventional] narratives miss the real story, which I’ve previously described as a cascade effect. This is the downward pressure on underrepresented students to accept weaker offers (offers charging higher tuition with less aid) to less selective law schools due to the tightening of…