Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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Bernie Moreno and Elizabeth Warren: Our Plan to Save Social Security
In a guest essay for the New York Times, Bernie Moreno (R-OH) and Elizabeth Warren (D-MA) argue for their plan “to save Social Security for generations of Americans to come.” From the piece: That starts with a common-sense solution: lifting the Social Security payroll tax cap. For 2026, the payroll tax cap, or taxable maximum,…
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Tax Notes: Soroban Gets Cool Reception on Limited Partner Argument
Kristen A. Parillo, in Tax Notes, provided an update on the oral argument in Soroban Capital Partners LP v. Commissioner, the Second Circuit case in which a taxpayer is challenging the government’s interpretation of the term “limited partner” in section 1402(a)(13): A panel of Second Circuit judges seemed highly skeptical of a New York hedge fund’s…
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Bankman et al: Home Production and the Income Tax
Joseph Bankman (Stanford), Jacob Goldin (Chicago), Adam Kern (San Diego), and Ana Vasilj (Chicago) have posted “Buy or D.I.Y.: Home Production and the Income Tax” on SSRN (and forthcoming in the Columbia Law Review). Here is the abstract: The income tax aspires to be comprehensive-a tax on “all income, from whatever source derived.” Yet every…
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DOJ Tax is Hiring
Trevor Sikes, “DOJ Seeks More Tax Attorneys as Caseload Increases” (Tax Notes, June 29, 2026): The Justice Department’s Tax Litigation Branch of the Civil Division is looking to bolster its workforce following a significant exodus of attorneys and an increased caseload, according to a government official. “During the last couple of years, we’ve lost some significant amount of…
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Newsom Floats Federal Wealth Tax After California Deal Fails
Alicia Clanton & Biz Carson (Bloomberg Law): Newsom Floats Federal Wealth Tax After California Deal Fails Governor Gavin Newsom is calling for a federal tax on billionaires after failing to stop a California wealth tax from reaching the November ballot, setting up a high-profile test of whether voters will back one of the nation’s most…
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Herzfeld: “SpaceX Speculation: Who Bears the Risk?”
Mindy Herzfeld (Florida), SpaceX Speculation: Who Bears the Risk?, 191 Tax Notes Fed. 2235 (June 29, 2026) But investors are presumably buying SpaceX shares on the expectation that the company will eventually become profitable. Assuming that happens, one question is how its business income might be taxed in the United States and elsewhere. Also of…
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Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case
David Schultz & Michael Rapoport (Bloomberg Law): Coca-Cola Meets Sympathetic Judges in $20 Billion IRS Case A panel of federal appellate judges were receptive to Coca-Cola Co.’s arguments that the IRS improperly allocated its foreign income in a case that could cost the soft drink company up to $20 billion.
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Florida Tax Review Publishes New Issue
The Florida Tax Review has published Vol. 29, No. 1 (Fall 2025):
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NY Times: Congress Should Reform Endowment Tax to Incentivize More Wealthy Colleges to Expand Access to Working- and Middle-Class Students
New York Times Op-Ed: A Bold Idea to Open Up Elite Colleges, by James S. Murphy (Fellow, Class Action) & Ryan Cieslikowski (Co-Founder & Director, Class Action): Princeton recently waived tuition for most students from families making up to $250,000 a year. Reporting in The Daily Princetonian suggests that this move may have removed the university from…
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Trump Threatens 100% Tariffs in Response to European DSTs
In another iteration of the Trump Administration’s long-running opposition to digital services taxes, President Trump on Friday threatened to impose 100% tariffs on all imports from countries that impose or move forward with DSTs. Trump said that the tariff would supersede other trade agreements—most centrally the deal struck last year with the European Union that…
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George, Yoon & Gulati: Stacking the Deck
Tracey E. George (Vanderbilt), Albert Yoon (Toronto) & Mitu Gulati (Virginia), Stacking the Deck (May 29, 2026):
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Ehling et al.: Tax Revenue from Realized Capital Gains
Paul Ehling (BI Norwegian Bus. Sch.), Stathis Tompaidis (Texas, McCombs Sch. Bus.) & Chunyu Yang (BI Norwegian Bus. Sch.), Tax Revenue from Realized Capital Gains, 30 Rev. Fin. 863 (2026):
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TIGTA: The IRS Provided Addresses for Nearly 47,000 Persons to ICE
In early June, the Treasury Inspector General for Tax Administration released a lightly redacted report on the IRS’s implementation of its April 2025 data-sharing agreement with the Department of Homeland Security and U.S. Immigration and Customs Enforcement. The report focuses on the IRS’s processes and controls for responding to ICE requests for taxpayer address information,…
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SSRN Review & Roundup: Eyal Reviews Hemel’s Madisonian Nonprofit Law and Checks and Balances
This week, Mirit Eyal (Alabama; Google Scholar) reviews a new work by Daniel J. Hemel (NYU; Google Scholar), Madisonian Nonprofit Law and Checks and Balances, 64 Harv. J. Leg. (forthcoming 2027): The role of nonprofits in American democracy has become increasingly salient. As universities, charities, religious institutions, and advocacy groups face mounting political pressure, Hemel’s…
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WSJ: California’s Billionaire Tax Kicks Off a Democratic Civil War
Paul Kiernan and Laura J. Nelson, California’s Billionaire Tax Kicks Off a Democratic Civil War (Wall Street Journal, June 25, 2026) California’s proposed billionaire tax will appear before voters in November, teeing up a fight among Democrats over wealth, affordability and the future of their party as they push to take back Congress in this…
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Taxpayer Advocate Service: Releases FY 2027 Objectives Report to Congress
Taxpayer Advocate Service: Advocate Service: Releases FY 2027 Objectives Report to Congress: The Internal Revenue Code requires the National Taxpayer Advocate to submit two annual reports to the House Committee on Ways and Means and the Senate Committee on Finance. The National Taxpayer Advocate is required to submit these reports directly to the Committees without…
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Miami Law Seeks Visiting Faculty for ’26-’27
Miami: Seeking Visiting Faculty for ’26-’27: The University of Miami School of Law is pleased to announce that it is currently seeking applicants for visiting professor position(s) for the Fall 2026 and Spring 2027 semesters. The law school has a number of curricular needs but is especially interested in candidates specializing in environmental, tax, labor,…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 50 (June 2026) of the Journal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron:
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Federal Circuit Permits Section 122 Tariffs to Proceed
In a per curiam order, the Federal Circuit ruled that that the tariffs imposed under section 122 of the Trade Act of 1974 could continue to be collected. The order was in response to a motion to stay the judgment of the Court of International Trade, which had ruled the tariffs were unlawful back in…
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Clouse et al.: California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits
In Tax Notes, Jim Clouse, Fabio Natalucci, Charles W. Calomiris, Kenneth Rosen, David Bank, and Maxwell Hall, have written a new piece, “California’s Billionaire Tax Act Threatens Growth and Fails to Address Structural Deficits.” From the introduction: The dire fiscal outlook for the state of California has prompted numerous proposals for ways to increase state…
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Tax Law Center: How Congress Should Quickly Block the President’s Get-out-of-Tax-Free Card
Brandon DeBot and Kelsey Merrick from the Tax Law Center have published a new blog post, “How Congress Should Quickly Block the President’s Get-out-of-Tax-Free Card.” From the piece: Members of Congress and observers across the political spectrum have criticized the Administration’s attempts to give the President, his family, and his affiliates an extraordinary release of…
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Supreme Court Tells Us What “Just Compensation” Means in a Tax Sale
The Supreme Court just decided Pung v. Isabella County. The case resolves a question left open by Tyler v. Hennepin County (2023): when the government forecloses on and sells property to satisfy a tax debt, is “just compensation” under the Takings Clause measured by the tax-sale auction price or by fair market value? Writing for…
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California Billionaire Tax Qualifies for November Ballot
Paul Jones, “California Billionaire Tax Qualifies for November Ballot” (Tax Notes, June 22, 2026): The California ballot initiative proposing a one-time billionaire wealth tax has qualified for the November ballot. But the success for proponents comes as some labor groups and traditionally progressive groups have now joined business interests and antitax groups in opposition to…
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King Charles to Reveal Personal Taxes
Sean Coughlan, “King Charles to reveal personal tax bill for first time as monarch” (BBC, June 21): King Charles will become Britain’s first monarch in modern times to reveal his personal tax bill. His tax payments will be shared on Thursday as a new element in the annual royal financial accounts, with the decision said…
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Florida Voters Will Decide Fate of Property Tax Relief Plan
Billy Hamilton (Tax Analysts): Florida Voters Will Decide Fate of Property Tax Relief Plan What makes this chain of events particularly interesting is that it combines three important trends in state and local tax policy and politics into a single issue. The first is the legislative desire, particularly in red states, to continue reducing taxes…