Brian D. Galle | Lightnews

Brian Galle @bdgesq.bsky.social · 13h

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.)

Roosevelt Institute @rooseveltinstitute.org · 13h

The admin is quietly rewriting the tax code—giving billions in breaks to major private equity, crypto, insurance, and energy firms by hollowing out the 15% corporate minimum tax.

More tax cuts for the rich is the last thing working families need.

@jessedrucker.bsky.social https://nyti.ms/3WOwXST

How the Trump Administration Is Giving Even More Tax Breaks to the Wealthy

The Treasury Department and Internal Revenue Service are issuing rules that provide hundreds of billions of dollars in tax relief to big companies and the ultrarich.

nytimes.com

Roosevelt Institute @rooseveltinstitute.org · 13h

The admin is quietly rewriting the tax code—giving billions in breaks to major private equity, crypto, insurance, and energy firms by hollowing out the 15% corporate minimum tax.

More tax cuts for the rich is the last thing working families need.

@jessedrucker.bsky.social https://nyti.ms/3WOwXST

How the Trump Administration Is Giving Even More Tax Breaks to the Wealthy

The Treasury Department and Internal Revenue Service are issuing rules that provide hundreds of billions of dollars in tax relief to big companies and the ultrarich.

nytimes.com

Brian Galle @bdgesq.bsky.social · 1d

Source: ProPublica share.google/VJUGMnGSNOUQ...

Brian Galle @bdgesq.bsky.social · 5d

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

Brian Galle @bdgesq.bsky.social · 8d

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...

Brian Galle @bdgesq.bsky.social · 9d

I previewed the litigation against Education's new public service loan forgiveness rule for Inside Higher Ed:

www.insidehighered.com/news/governm...

ED Finalizes PSLF Rule Limiting Who Gets Forgiveness

The department says fewer than 10 employers will be affected a year, but advocates fear the rule could set “a troubling precedent.”

www.insidehighered.com

Brian Galle @bdgesq.bsky.social · 11d

Pass-throughs?

Brian Galle @bdgesq.bsky.social · 11d

For skeptical comments of leading nonprofit-law experts (+me) on the proposed rule -- many (but, crucially for APA purposes, not nearly all) of them hand-waved at by the final rule's preamble -- see here: www.regulations.gov/comment/ED-2...

Regulations.gov

www.regulations.gov

Brian Galle @bdgesq.bsky.social · 11d

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.

public-inspection.federalregister.gov

Brian Galle @bdgesq.bsky.social · 13d

From OpenAI, you mean? That's my sense. The AG could have held this transaction up a long time if they had been so inclined. Whether, as you say, it ultimately binds is open q. given the history of the sub controlling its parent board, weakness of np law, etc.

Brian Galle @bdgesq.bsky.social · 13d

OpenAI, a charity, gets to effectively sell off a part of its stake in ChatGPT. But in exchange, it makes fairly unprecedented promises to still be good and ensure the charity remains in control of the company that will operate the ChatGPT enterprise.

Brian Galle @bdgesq.bsky.social · 13d

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.

Jesse @jessemerle.bsky.social · 13d

And just seeing this CA AG Bonta memo too

oag.ca.gov/system/files...

Jesse @jessemerle.bsky.social · 13d

And just seeing this CA AG Bonta memo too

oag.ca.gov/system/files...

Brian Galle @bdgesq.bsky.social · 13d

This structure also protects against a key weakness of public benefit corps (the structure the for-profit sub is now using). As @islandtaxprof.bsky.social has explained, B-corps are vulnerable to hostile takeovers by profit maximizers. That will be very tough to do with no access to board seats.

Brian Galle @bdgesq.bsky.social · 13d

When I was commenting for reporters last week, I assumed that there would be more of a spin-off deal in which the nonprofit would get nothing but cash. This structure, in which the nonprofit retains overwhelming (formal) control, is a big win for those who want to see continuing guardrails.

Brian Galle @bdgesq.bsky.social · 13d

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.

Our structure

We designed OpenAI’s structure—a partnership between our original Nonprofit and a new capped profit arm—as a chassis for OpenAI’s mission: to build artificial general intelligence (AGI) that is safe a...

openai.com

Patriotic Millionaires @patrioticmillionaires.org · 14d

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...

‘Billionaire tax’ ballot measure seeks to avert CA health care collapse

Two health care industry players propose a one-time 5% tax on billionaires to offset federal cuts to Medi-Cal, education.

www.sacbee.com

Brian Galle @bdgesq.bsky.social · 14d

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...

Brian Galle @bdgesq.bsky.social · 15d

Fair -- there might be as many as a handful of people for whom the phase-in could affect planning (but n.b. only moves during 2025 affect the tax). Also, Forbes will send you the more-detailed spreadsheet if you click the "request" button and then agree to receive spam from them in perpetuity.

Brian Galle @bdgesq.bsky.social · 16d

Not quibbling with the math, but since the data on CA billionaires and their wealth is publicly available via Forbes, I would urge PE and its readers to check out how many individuals are in the phase-in range (ahem, it's 1).

Brian Galle @bdgesq.bsky.social · 17d

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...

If you’re reading this and you’re a California billionaire, hide your wallet

A new ballot initiative seeks a combined one-time tax of $100 billion from California’s richest.

sfstandard.com

Brian Galle @bdgesq.bsky.social · 18d

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!

David Dayen @ddayen.bsky.social · 18d

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.

David Dayen @ddayen.bsky.social · 18d

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.

Brian Galle @bdgesq.bsky.social · 18d

Many people are saying!

www.theatlantic.com/ideas/archiv...

Brian Galle @bdgesq.bsky.social · 20d

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?

NBER @nber.org · 20d

Wolves found only north of the Saint Lawrence River in Canada reduce animal-related vehicle collisions by 5 percentage points—providing an empirical quantification of quasi-option value, from Eyal G. Frank, Anouch Missirian, Dominic P. Parker, and @jenraynor.bsky.social www.nber.org/papers/w34377

NBER @nber.org · 20d

Wolves found only north of the Saint Lawrence River in Canada reduce animal-related vehicle collisions by 5 percentage points—providing an empirical quantification of quasi-option value, from Eyal G. Frank, Anouch Missirian, Dominic P. Parker, and @jenraynor.bsky.social www.nber.org/papers/w34377

Brian Galle @bdgesq.bsky.social · 21d

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!

Brian Galle @bdgesq.bsky.social · 28d

Public schools are exempt under 1930s-era IRS rulings on quasi-sovereign entities. But donations to them are still limited by the "exclusively public" language, see IRS 170(c).

So if a public accepts the offer, it would prob. still be tax-exempt, but unable to receive tax-deductible donations.

3/3

Brian Galle @bdgesq.bsky.social · 28d

The problem in accepting is that the offer requires schools to refund donations to donors if the school violates the offer terms. That contravenes the 501(c)(3) rule that all donations are irrevocable. Similarly, donations to any entity are deductible only if for "exclusively public purposes."

2/3

Brian Galle @bdgesq.bsky.social · 28d

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...

Trump Offers All Colleges Preferential Funding Plan Rejected by MIT

The Trump administration is inviting all US colleges to participate in a compact — initially rejected by the Massachusetts Institute of Technology — that would grant preferential federal funding in re...

www.bloomberg.com

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