Paul L. Caron
Dean
Pepperdine Caruso
School of Law
Tax
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WSJ: Rich Californians Are Finding Creative Ways to Get Ahead of the Billionaire Tax
Juliet Chung (WSJ): Rich Californians Are Finding Creative Ways to Get Ahead of the Billionaire Tax With help from their phalanx of tax and trust-and-estate advisers, California’s ultrawealthy are getting creative in the face of the proposed billionaire tax. If it becomes law, it would tax the net worth of billionaires who resided in California…
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Bloomberg: Coca-Cola, IRS Face Off in Tax Appeal With Huge Stakes for Both
Michael Rapoport & David Schultz (Bloomberg Law): Coca-Cola, IRS Face Off in Tax Appeal With Huge Stakes for Both The beverage giant and the government will square off in oral arguments [on June 25] before the US Court of Appeals for the Eleventh Circuit in Miami. Coca-Cola is appealing US Tax Court rulings that side…
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Columbia Journal of Tax Law Publishes New Issue
The Columbia Journal of Tax Law has published a new issue (Vol. 17, No. 2 (Spring 2026)): Jason S. Oh (UCLA), Taxing Subjective Value: Floors as a Response to Heterogeneity, 17 Colum. J. Tax L. 93 (2028): This Article takes a fresh look at the problem of taxpayer heterogeneity—how the same good or service can…
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Jim Gadwood, Vice Chair of Miller & Chevalier’s Tax Department, May Be Next IRS Chief Counsel
Bloomberg Law, Tax Controversy Lawyer Is in Line for Top Counsel Job at IRS: Private-sector lawyer Jim Gadwood is being vetted to become IRS Chief Counsel, according to a person familiar with the process. If confirmed, he would be the fourth person in the role since President Donald Trump took office. … Gadwood, now vice…
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Congressional Tax Agenda Stalls as Trump Continues to Use Administrative Levers
As midterms approach, the timeline for tax legislation in this Congress becomes more compressed. This week brought bad news for two of the most plausible tax packages currently in play—and lower odds of major substantive tax action in 2026. The striking point is that distinct pressures are stalling legislative action on both a partisan and…
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Reuters: U.S. Law Schools See Sharp Drop in International LL.M. Applications
Drawing on LSAC data, Reuters reports that the number of LL.M. applicants to U.S. law schools fell by 14% in 2025–2026, driven by declines in applicants from China (by 21%) and India (by 23%). For specific schools, LL.M. applications to UC Berkeley and Michigan dropped by 20% and 30%, respectively. Columbia, NYU, Harvard, and Georgetown—law…
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Acquah-Sarpong et al.: Do Tax Cuts Ease Liquidity Constraints?
Richard Acquah-Sarpong (Oregon State, Dept. Applied Econ.), Yong Chen (Oregon State, Dept. Applied Econ.), David Guo (Wichita St., Wall Sch. Pub. Affairs) & Paul Lewin (Idaho, W. Rural Dev. Ctr.), Do Tax Cuts Ease Liquidity Constraints?, Int’l Tax & Pub. Fin. (May 15, 2026):
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Bloomberg Tax: Colombia Seeks Shield for Multinationals From Global Minimum Tax
Somesh Jha & Saim Saeed, Colombia Seeks Shield for Multinationals From Global Minimum Tax, Daily Tax Report (June 19, 2026): [Columbia] has submitted a formal request for a [Pillar 2] carve-out [under the UPE safe harbor] to the Organization for Economic Cooperation and Development . . . . The safe harbor would allow the top-up…
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SSRN Review & Roundup: Elkins Reviews Li’s Pillar 2 as a New International Fiscal Law
This week David Elkins (Netanya) reviews a new work by Jinyan Li (York), Pillar 2 as a New International Fiscal Law, 121 Tax Notes Int’l 637 (Jan. 26, 2026): In this week’s feature article, Professor Jinyan Li examines the transformative impact of Pillar 2, the global initiative designed to ensure that large multinational enterprises (MNEs)…
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WSJ: Being Generous to Your Kids? Don’t Stick Them With a Surprise Tax Bill
Laura Saunders, Being Generous to Your Kids? Don’t Stick Them With a Surprise Tax Bill (Wall Street Journal, June 19, 2026) Are you feeling generous toward your children or grandchildren? Before opening your wallet, check whether your largess could yield a surprise tax bill for them. The reason is the “kiddie tax,” an often-overlooked levy…
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WSJ: Rhode Island Joins the Tax Race to the Top
Wall Street Journal Editorial Board, Rhode Island Joins the Tax Race to the Top (June 15, 2026) Rhode Island Gov. Dan McKee’s five-year record has made him vulnerable to a primary challenge as he seeks re-election this year. Now he’s further punishing his state by signing a millionaire’s tax to win the support of government unions.…
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NY Times: Union Behind California Billionaire Tax Offers to Reduce the Rate
Laurel Rosenhall, Union Behind California Billionaire Tax Offers to Reduce the Rate (New York Times, June 18, 2026) With just days left to negotiate over a ballot proposition that would ask California voters to impose a one-time tax on billionaires, the union behind the measure is trying to strike a deal. It sent Gov. Gavin…
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Bloomberg: Varian Owes $7 Million After Tax Court Sunk Dividend Deductions
James Matheson (Bloomberg): Varian Owes $7 Million After Tax Court Sunk Dividend Deductions: Global medical manufacturer Varian Medical Systems Inc. is liable for a $7.3 million tax deficiency after a prior US Tax Court opinion disallowed some of the dividend deductions the company claimed for its 2018 tax year, according to a stipulated decision entered in the…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 49 (June 2026) of the eJournal of Tax Law and Policy, published by The Social Science Research Network (SSRN), and edited by Paul L. Caron: Jinyan Li (York University), Offshore Tax Havens: An Intriguing Problem for Canadian Tax Law Harry P. Dale (New York), Daniel J. Hemel (New York), Jill S. Manny (New York), DAF Sponsors…
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WSJ: Jalen Brunson’s Tax Wisdom
Wall Street Journal, Editorial Board, Jalen Brunson’s Tax Wisdom: Jalen Brunson is the toast of New York after the 6-foot-2 point guard personally willed the New York Knicks to the NBA title on Saturday with a 45-point performance. The rest of his team scored 49. But it appears there’s another reason for New Yorkers to like the basketball…
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Legal Scholarship Network Publishes New Issue of Tax Law & Policy eJournal
Volume 26, Number 48 (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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New Issues of The Tax Lawyer
The Tax Lawyer has published two new issues. Vol. 78, No. 4 (Summer 2025) Vol. 79, No. 1 (Fall 2025) State & Local Tax Griswold Lecture
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UC Davis School of Law Summer Tax Institute
I actually have something about tax law to post! Summer Tax Institute, June 15 – 18, 2026, UC Davis School of Law The 36th annual Summer Tax Institute, with, among others, UC Davis School of Law Professors Darien Shanske and Dennis Ventry, is in session! It is an intensive, 4-day educational program for tax professionals. Classes qualify…
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New Reports by NYSBA Tax Section
The New York State Bar Association’s Tax Section has recently released two new reports concerning (1) amendments to section 4968 and (2) selected issues under section 108(e)(6):
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TaxProf Blog Op-Ed: Avi-Yonah on “When Is a Fee a Tax?”
This TaxProf Op-Ed on the recent decision in California v. Mullin is by Reuven S. Avi-Yonah (Michigan): When Is a Fee a Tax? Reuven S. Avi-Yonah On June 8, 2026, US District Judge Leo T. Sorokin (D. Mass.) issued an opinion invalidating the $100,000 payment that the Trump administration had imposed on applications to obtain…
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Government Seeks to Resume Taxpayer Info Sharing With ICE
Trevor Sikes, “Government Seeks to Resume Taxpayer Info Sharing With ICE” (Tax Notes, June 16, 2026): An injunction against the sharing of taxpayer data between the IRS and U.S. Immigration and Customs Enforcement was improperly granted and is hindering criminal law enforcement efforts, according to the Justice Department. In its June 12 appellate brief to the First Circuit in CEDC v. Bessent, the…
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Junior Tax 2026 Concludes at Seattle University
The 2026 Junior Tax Conference took place on June 12 and 13 at Seattle University School of Law. (Many thanks to Luke Maher for hosting!) Here are the sixteen projects presented and discussed across the two days:
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Fox and Liscow: The Rich’s Real Tax Trick Isn’t ‘Buy, Borrow, Die’
Edward Fox (Michigan) and Zachary Liscow (Yale), “The Rich’s Real Tax Trick Isn’t ‘Buy, Borrow, Die’” (Tax Policy Center, June 15, 2026): A fashionable theory of how the rich avoid taxes captures something real—but it misses what’s mostly going on. Consider two of the wealthiest billionaires in the US: Jeff Bezos and Elon Musk. The theory…
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Illinois Enacts Several New Digital Taxes
Illinois recently enacted just about every conceivable digital tax as part of the state’s budget legislation, including a: More detail below the fold.
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SALT Deduction Cap Falls Short in Design, Not Constitutionality
Andrew Leahey (Drexel/Bloomberg Law): SALT Deduction Cap Falls Short in Design, Not Constitutionality The latest defeat of a constitutional challenge to the state and local tax deduction cap underscores that the cap’s real defect isn’t that Congress lacked the power to enact it. It’s that Congress used its power to create a blunt, politically punitive tax rule…