Brian Galle
@bdgesq.bsky.social
Berkeley law prof guy, erstwhile Georgetown, DOJ, & points in between. Mostly boring tax stuff; occasional dollops of nonprofits, law & econ, etc. Could be arguing in my spare time.
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...
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...
Opinion | California’s wealth-tax test
Have voters finally found a policy that the state’s inherent economic strengths can’t overcome?
www.washingtonpost.com
November 20, 2025 at 10:04 PM
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...
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."
*: A boot camp in S. Carolina run by DOJ -- kinda like the movie Stripes, but with a lot of bad suits -- call it "PinStripes."
November 19, 2025 at 6:41 PM
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."
*: 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'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...
washingtonian.com/2025/11/13/h...
How a Top DC Lawyer and High-Stakes Poker Player Risks Losing It All
Tom Goldstein lived a double life—and is now fighting federal charges for alleged financial crimes. Why did he risk it all to play cards?
washingtonian.com
November 19, 2025 at 2:58 AM
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...
washingtonian.com/2025/11/13/h...
This is a family-friendly account, so not gonna post the Surfer Rosa album cover. But it did drop when I was 16.
November 17, 2025 at 2:31 AM
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.)
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
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
November 10, 2025 at 6:42 PM
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.)
Reposted by Brian Galle
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...
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...
ADMIN LAW AND THE CRISIS OF TAX ADMINISTRATION
ADMIN LAW AND THE CRISIS OF TAX ADMINISTRATION, Brian Galle & Stephen Shay
northcarolinalawreview.org
November 28, 2023 at 3:16 PM
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...
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.
November 5, 2025 at 4:29 PM
I must say I genuinely believed that the MQD only applied to administrative action by Democrats.
Reposted by Brian Galle
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...
www.wsj.com/opinion/a-un...
(paywall, sorry)
For more on the tax, see www.seiu-uhw.org/ca-billionai...
October 27, 2025 at 6:06 PM
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...
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...
www.npr.org/2025/11/01/n...
November 2, 2025 at 7:33 PM
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...
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...
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
November 2, 2025 at 12:01 AM
I previewed the litigation against Education's new public service loan forgiveness rule for Inside Higher Ed:
www.insidehighered.com/news/governm...
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.
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
October 30, 2025 at 6:34 PM
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.
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.
October 29, 2025 at 12:25 AM
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.
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
October 28, 2025 at 5:37 PM
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.
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.
Reposted by Brian Galle
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...
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
October 27, 2025 at 7:53 PM
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...
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...
www.wsj.com/opinion/a-un...
(paywall, sorry)
For more on the tax, see www.seiu-uhw.org/ca-billionai...
October 27, 2025 at 6:06 PM
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...
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...
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
October 24, 2025 at 3:13 PM
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...
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.
It will be announced today.
October 23, 2025 at 3:09 PM
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!
Reposted by Brian Galle
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.
It will be announced today.
October 23, 2025 at 2:33 PM
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.
It will be announced today.
October 23, 2025 at 2:14 PM
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?
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
October 21, 2025 at 5:20 PM
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!
October 20, 2025 at 4:01 PM
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...
(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
October 13, 2025 at 11:48 PM
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...
(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.
“The problem with billionaires isn’t that they’re hoarding money that would otherwise pay for a Scandinavian social utopia. It’s that their money has become a source of wildly distorted political power that allows a few men with extremist views to wreak havoc on the rest of us.”
Billionaires Are Hoarding Power, Not Money
Billionaire money has become a source of wildly distorted political power that allows a few men with extremist views to wreak havoc on the rest of us.
www.liberalcurrents.com
October 10, 2025 at 2:02 PM
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.