This write-up of the #CABillionaireTax gets several key points wrong. First, it complains that small businesses are hard to value, but the bill has a simple formula for that task that is already in use in Switzerland and Spain. www.forbes.com/sites/robert... 1/4

Surprise! The Bezos Post doesn't like taxing billionaires. www.washingtonpost.com/opinions/202... Readers, do I need to point you to the real facts on taxpayer mobility? OK, one more time: www.theatlantic.com/ideas/archiv...

This, friends, is why they teach you in prosecutor school* not to wait until the last day of the statute of limitations to file your indictment. *: A boot camp in S. Carolina run by DOJ -- kinda like the movie Stripes, but with a lot of bad suits -- call it "PinStripes."

I think they're trolling you, @omrimarian.bsky.social www.bloomberg.com/news/article...

I'm quoted in this sad story about Tom Goldstein, delivering the unfortunate news that this is not the bs Hunter Biden tax charges or this DOJ's usual clown show. Lead prosecutor here was fraud chief in SDNY and the indictment is the real stuff. washingtonian.com/2025/11/13/h...

Some new reads on the #CABillionaireTax: www.forbes.com/sites/nathan...

This is a family-friendly account, so not gonna post the Surfer Rosa album cover. But it did drop when I was 16.

The repost just below this one in my feed explains how it is that IRS has the power to declare its own tax holidays. Might be a bad idea, some have said! (I'd favor allowing 3d parties to appeal giveaways to Tax Court, where Article III standing rules do not apply.)

Good WSJ write-up of the IRS's unchallengeable power to create tax breaks (albeit disappointingly short of 80s tunes references), with quotes from me. taxprof.typepad.com/taxprof_blog... For much, much more on that problem and what to do about it, see: northcarolinalawreview.org/2023/08/29/l...

I must say I genuinely believed that the MQD only applied to administrative action by Democrats.

We just introduced the #CABillionaireTax and already the Wall Street Journal is...is...huh. Is apparently running op-eds in support? www.wsj.com/opinion/a-un... (paywall, sorry) For more on the tax, see www.seiu-uhw.org/ca-billionai...

My erstwhile BC colleague Ray Madoff (no relation to that guy) on NPR talking about her book "The Second Estate" and making a great case for mark-to-market taxation for the ultra-rich: www.npr.org/2025/11/01/n...

I previewed the litigation against Education's new public service loan forgiveness rule for Inside Higher Ed: www.insidehighered.com/news/governm...

Education has issued its final public service loan forgiveness rule. public-inspection.federalregister.gov/2025-19729.pdf As expected it is awful and not much changed from the PR. Pretty hard to take seriously the idea that you can respond to 14,000 comments in 1.5 months. We'll see 'em in court.

This is a remarkable document. In particular I have never seen an entity agree that the AG not only has continuing supervisory authority, but that the entity will pay the AG's costs of exercising that power, including the costs of experts.

OpenAI's doc on their new structure is a fascinating read for nonprofit types: openai.com/our-structure/ Key point: the nonprofit parent appoints the entire board of the for-profit sub. I can't imagine it was their 1st choice to give investors 0 board seats, suggesting tough negotiating by the AG.

A one-time, 5% tax on the state’s billionaires is a common-sense solution that ensures the richest in California pay back into a system that enables their success. Hopefully inspires other states and cities around the country to do the same and #TaxTheRich: www.sacbee.com/news/politic...

We just introduced the #CABillionaireTax and already the Wall Street Journal is...is...huh. Is apparently running op-eds in support? www.wsj.com/opinion/a-un... (paywall, sorry) For more on the tax, see www.seiu-uhw.org/ca-billionai...

Pretty good writeup of the California Billionaire Tax ballot proposal (scripted in part by the usual suspects, i.e. me, @davidgamage.bsky.social and Darien Shanske) that dropped yesterday. sfstandard.com/2025/10/23/c...

Architect here. If any other states want to fill coffers that the feds have emptied, and want to build a fairer tax system that asks billionaires to finally pay more like a fair share, my DMs are open!

California is readying a one-time 5% tax on billionaires for the 2026 ballot that would go toward compensating for Trump's Medicaid cuts. The architects see it as a national model. It will be announced today.

Many people are saying! www.theatlantic.com/ideas/archiv...

So I & @brendansmaher.bsky.social did not include wolves in our 2018 list of in-kind redistribution mechanisms, but maybe we can get the pack back together for a follow-up?

Looking forward to joining @mikemadowitz.bsky.social and @rooseveltinstitute.org this week to discuss my forthcoming monograph, "How to Tax the Rich." With amazing special guests / commenters Kitty Richards and Greg Leiserson. Watch this space for more book previews!

Private schools that accept the POTUS offer would end their 501(c)(3) status. Publics are trickier, because--little-know fact---most of them aren't c(3)'s at all. What happens to them if they accept? Some thoughts. (1/3) www.bloomberg.com/news/article...

I have a book-length exploration of the economic and tax policy implications of this fact coming next month with @rooseveltinstitute.org : "How to Tax the Rich." You're going to like the retail price (it starts with 0 and ends with 0). Have your download fingers ready.

Just to develop the tax / nonprofit angle a bit more, the last sentence (allowing donors to claw back donations) would violate every 501(c)(3) organization's governing documents, and make them ineligible for deductible contributions. State orgs a little more complicated but likely same result.

We're grateful for this generous Jotwell write-up of "Taxing Dynasties" from Kent Schenkel (who is seemingly not on bsky). trustest.jotwell.com/a-prescripti...

We all know that Fed governor Lisa Cook was not fired "for cause." Indeed, in court, the administration will surely argue that for-cause protections are unconstitutional. Most other scholars say that recent decisions on indep. agencies portend an admin win on this issue. Aziz Huq & I disagree. 🧵

Unpopular opinion right now, but I do think the Fed can be said to have a different constitutional status than other independent agencies. Ofc, they all should be constitutional. But the Fed is different, because w/out it the borrowing power would be useless. lawreview.uchicago.edu/print-archiv...

Since IRS is within "all executive agencies," this directive appears to violate the criminal prohibition on presidents ordering tax audits. www.law.cornell.edu/uscode/text/...

The proposed 2% "Zucman Tax" on wealth in France is garnering huge crowds and overwhelming support. It's reveals the political durability of proposals to tax the rich, as Harold Meyerson writes. prospect.org/economy/2025...

If anyone noticed a little rattle in Berkeley this morning, that was me dropping my manuscript on some commenters. Sorry.

From what I'm hearing we're about to explore the legal boundaries of www.law.cornell.edu/uscode/text/...

Read the entire thread. See also www.regulations.gov/comment/ED-2... - co-written by several of the brightest minds and academics in the area of nonprofit and tax exemption law.

A impressive team of nonprofit law experts (+me), have banded together to comment on the new proposed rules from the Education Dept. on public service loan forgiveness. The rule purports to give ED authority to strip PSLF eligibility from any employer that acts with an "illegal purpose." 🧵 1/13

Not that I disagree with the general point, but avoiding estate tax is a complex & time-consuming dance, which is to say that the system arbitrarily rewards those who can hire the best dance instructors. More here: papers.ssrn.com/sol3/papers....

Another reason that encouraging tips, whether through the tax system or otherwise, is bad economic policy. Tips make workers (very) junior partners in the business, with much of the volatility but none of the control or bankruptcy cushion business owners enjoy.

No, Area 53-Year-Old Would Not Like His Drink With Boba

The holding that "pocket recissions" are illegal starts at page 31.

The Vdare 990's are certainly fishy. E.g., the 2023 990 reports that the org spent > $500,000 on "legal fees" (more than 1/3 of all expenses), yet does not disclose any legal services provider as one of its top-5 most highly compensated contractors (the whole field is blank).

We all know that Fed governor Lisa Cook was not fired "for cause." Indeed, in court, the administration will surely argue that for-cause protections are unconstitutional. Most other scholars say that recent decisions on indep. agencies portend an admin win on this issue. Aziz Huq & I disagree. 🧵

Coming from DC, where developers were frantically building 10-story condos for a couple of years before the new NoMa station even opened, the lack of development near BART stations is just baffling. The North Berkeley BART stop is basically an empty field, some ranch-style houses, and a tumbleweed.

First day of class, internet. What statutory interpretation classic lesson plan am I teaching today?

Once again I am puzzled about the reporting of the church/politics settlement. This is a deal a Harris administration probably would have happily made (since the alternative is an Alito opinion you know will be awful). It doesn't bind any future admin. Settle down. www.nytimes.com/2025/07/30/u...

At SEC we had to write 500-page explanations for our rules and still the 5th Circuit was like "nuh uh, moar regressions." Meanwhile, the complete explanation IRS gives for canceling Direct File is "I don't care about Direct File." news.bloombergtax.com/daily-tax-re...

Hit "send" on the first draft of my monograph with @rooseveltinstitute.org , "How to Tax the Rich." (Spoiler: no, the answer isn't "lots of tariffs"). Look out, @mikemadowitz.bsky.social ! Interested persons should feel free to email for advanced access.

To answer your urgent questions, no, I did not pose for this art after sticking my face in a bowlful of blueberries (though I would totally do that). I just have the natural coloration of a badger.

UC Berkeley Law has once again had a banner hiring year, adding seven new professors across a wide range of fields and disciplines to an already stellar faculty: www.law.berkeley.edu/article/seve... #UCBerkeleyLaw

Some interesting organizational-law questions in the Columbia settlement. If board members want to help government extort their own organization out of ideological alignment, is that self-dealing? If it helps board members avoid personal extortion? Something for the NY AG to think about.