Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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ABA Tax Section: Careers in Tax Webinar
ABA Tax Section, Careers in Tax Webinar on July 15 at 6:30 PM ET: The ABA Tax Section Outreach & Inclusion Committee invites undergraduate and law students to learn about pathways into taxation on July 15 from 6:30 – 7:30 pm ET. During this 60-minute discussion, our panel of accomplished tax professionals will share their…
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Bloomberg: California Film Tax Credit Demand Rises Under Expanded Program
Danielle Muoio Dunn (Bloomberg):California Film Tax Credit Demand Rises Under Expanded Program: California is seeing increased demand for its film and television tax credit program after expanding it to compete with similar incentives offered by New York and several European countries. The state saw an 82% increase in applications for the benefit this fiscal year compared to…
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Harpaz Presents “The New Tax Sovereignty” at The Junior International Law Scholars Association Summer Workshop
Assaf Harpaz (Georgia) will presented his article “The New Tax Sovereignty” at the Junior International Law Scholars Association summer workshop, as part of the international economic law group, on July 8, 2026. Here’s the abstract of the paper: Tax sovereignty is traditionally understood to encompass a government’s right to design and enforce its tax laws…
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Borden & Kaur: State Tax Enforcement of Section 1031 Proximate Exchanges
Bradley T. Borden (Brooklyn) and Lovepreet Kaur have published a new piece, “State Tax Enforcement of Section 1031 Proximate Exchanges,” 26 UC Davis Bus. L. J. 136 (2026). Here is the abstract: A section 1031 proximate exchange occurs when partners desire to transfer partnership property, separate, and separately complete section 1031 exchanges with their respective…
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N.Y. Times: Microsoft Disclosure Provides Rare Glimpse of Tax Haven Tactics
In the New York Times, Jesse Drucker and Karen Weise have a piece, “Microsoft Disclosure Provides Rare Glimpse of Tax Haven Tactics.” From the piece: A compliance report released by Microsoft this week provided a rare look into how tech giants shift profits out of the countries where they have many employees and significant sales…
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Rauh & Jaros: It Failed in France. It Would Be a Disaster in California.
In the New York Times, Joshua Rauh (Stanford Hoover Institute) and Benjamin Jaros (Stanford Hoover Institute) have published a guest essay titled, “It Failed in France. It Would Be a Disaster in California.” From the piece: To many, the 5 percent wealth tax on California’s ballot this year may sound like a harmless way to…
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Thorndike: The Forgotten Ancestor of AI Taxes
Joseph Thorndike, “Today’s AI Taxes Have a Forgotten Depression-Era Ancestor” (Tax Notes, July 6, 2026): Taken together, recent proposals for taxing AI can seem novel, even unprecedented — a creative response to the extraordinary pace of technological change and its rapid spread through the economy. The flurry may also reflect the staggering wealth accumulating around…
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Democracy Journal Publishes New Tax Symposium
Democracy: A Journal of Ideas, has recently published a tax symposium—focused on “why we need more tax revenue, and how to raise it”—that features a number of law professors, including contributions from Brian Galle, Lily Batchelder, and David Kamin (with Chye-Ching Huang and Brandon Debot of the Tax Law Center at NYU). The full set…
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Hemel: Madisonian Nonprofit Law and Checks and Balances
Daniel J. Hemel (NYU; Google Scholar), Madisonian Nonprofit Law and Checks and Balances, 64 Harv. J. Leg. (forthcoming 2027): The nonprofit sector is often described as a counterweight to the state. But how exactly do nonprofit organizations check and balance public power? This essay argues that nonprofits constrain government not only by confronting agencies as adversaries but…
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NY Tax on Remote Work Again Withstands Professor’s Challenge
Perry Cooper (Bloomberg Law): NY Tax on Remote Work Again Withstands Professor’s Challenge New York’s strict rules for taxing remote work performed for in-state companies survived another legal attack after a state appeals court ruled Thursday that they conform to federal constitutional protections. … Zelinsky asked the New York Supreme Court, Appellate Division, Third Department,…
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Kalshi Sues Illinois to Nullify New Prediction Market Tax Law
Emily Hollingsworth (Tax Analysts): Kalshi Sues Illinois to Nullify New Prediction Market Tax Law Kalshi has filed suit in federal court to prevent Illinois from enforcing its new prediction market tax and licensing requirements, which the company says will cause it “irreparable harms.” The prediction market company filed its June 23 complaint under KalshiEX LLC v. Raoul in the U.S.…
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The New York Pied-à-Terre Tax: What You Should Know
David Pope & Chris Lorimer (DLA Piper): The New York Pied-à-Terre Tax: What You Should Know, 121 Tax Notes State 19 (July 6, 2026) In this article, Pope and Lorimer review the newly enacted New York City pied-à-terre tax, including its two-phase valuation structure, rate schedule, exemptions, potential constitutional issues, and the Department of Finance’s…
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Brauner: A Purpose-based Reform of Income Sourcing Rules
Yariv Brauner (Florida), Income and Territory: A Purpose-based Reform of Income Sourcing Rules, 74 Can. Tax J. ___ (2026): Since the inception of the international tax regime in the twentieth century, states have been taxing income based on both the residence of taxpayers and the source of their income. Twenty-first-century developments have rendered this arrangement…
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Virginia Tax Review Publishes New Issue
The Virginia Tax Review has published Vol. 45, No. 2 (Fall 2025): Kristin E. Hickman (Minnesota) & Bridget C.E. Dooling (Ohio State), Delay, Politics, and Expertise in OIRA Tax Review, 45 Va. Tax Rev. 125 (2025): The opening months of the second Trump administration have featured a wide range of changes to federal policy accomplished through presidential …
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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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TPC: America at 250: Ten Tax Facts to Remember
Tracy Gordon & Aravind Boddupalli, America at 250: Ten Tax Facts to Remember, Tax Policy Center (June 29, 2026): The 250th anniversary of the signing of the Declaration of Independence marks a great time to think about taxes. . . .
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Roundup: The OBBBA, One Year Later
July 4 marks one year since the enactment of the One Big Beautiful Bill Act, and analysts across the tax policy spectrum are taking stock: who received tax relief (and how much), who bore (or will bear) the offsetting costs, and how the law has reshaped the American fiscal state and the trajectory of future…
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Tax Notes: Check, Please: Workers React to ‘No Tax on Tips’ One Year In
Trevor Sikes & A.J. Collins, Check, Please: Workers React to ‘No Tax on Tips’ One Year In (Tax Analysts, 2026 TNTF 127-4) The qualified tips deduction, known as “No Tax on Tips,” has been touted by the Trump administration as a win for middle-income Americans, but some tipped workers told Tax Notes that the provision didn’t provide…
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WSJ: Why a Couple Lost a $200,000 Tax Battle Over Their Horses
Laura Saunders, Why a Couple Lost a $200,000 Tax Battle Over Their Horses (Wall Street Journal, July 3, 2026) Lots of Americans lose battles with the Internal Revenue Service. But sometimes those fights provide insights the rest of us can use to win against the IRS on similar issues. A recent Tax Court case about so-called hobby…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 52 (June 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: North Carolina Targets Prediction Markets, Sports Betting Taxes
Daniel Moore (Bloomberg): North Carolina Targets Prediction Markets, Sports Betting Taxes: North Carolina lawmakers unveiled a $34 billion budget deal (SB 257) Tuesday that includes a new 6% prediction markets tax and higher levies on sports betting providers—the latest move by the state to extract more revenue from its growing gambling industry. The agreement announced…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 51 (June 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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The Tax Adviser: IRS outlines AI risks, Circular 230 duties for tax practitioners
Martha Waggoner (The Tax Adviser): IRS outlines AI risks, Circular 230 duties for tax practitioners: The IRS Office of Professional Responsibility (OPR) issued guidance outlining how existing Treasury Circular 230 rules apply to tax practitioners’ use of artificial intelligence (AI), emphasizing that long-standing duties such as due diligence, competence, and confidentiality remain unchanged. The overarching…
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Bearer-Friend et al.: Critical Tax Meets Law and Political Economy: A Conversation
Jeremy Bearer-Friend (George Washington), Bridget J. Crawford (Pace), Tessa Davis (South Carolina), Anthony C. Infanti (Pittsburgh), Ariel Jurow Kleiman (Southern California), Goldburn Maynard Jr. (Connecticut), Blaine G. Saito (Ohio State), and Clint Wallace (South Carolina) have a new piece forthcoming in the Ohio State Law Journal Online, “Critical Tax Meets Law and Political Economy: A…