News & Analysis as of

SALT Internal Revenue Service

Eversheds Sutherland (US) LLP

SALT Scoreboard - Quarter 2, 2024

This is the second edition of the Eversheds Sutherland SALT Scoreboard for 2024. Since 2016, we have tallied the results of what we deem to be significant taxpayer wins and losses and analyzed those results. Our entire SALT...more

Warner Norcross + Judd

Current Tax Laws That Will Expire After 2025 if Congress Does Not Act

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The Tax Cuts and Jobs Act (TCJA), which became effective on January 1, 2018, made significant changes to tax legislation that impacted individuals, families, business owners and companies. Some changes were intended to be...more

Alston & Bird

NIL Collectives: Don’t Be Blindsided by an IRS Challenge

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If the IRS challenges the tax-exempt status of a name, image, and likeness (NIL) collective, the collective must understand how best to respond. Our Federal Tax Group details what NIL collectives need to know to make the cut....more

Baker Donelson

SALT Select Developments - March 2024

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. ln this newsletter edition, we will briefly summarize selected state and local tax (SALT)...more

Kohrman Jackson & Krantz LLP

Maximizing Tax Benefits: Exploring SALT Cap Workarounds

Recently, the Wall Street Journal published an article entitled “The SALT Cap Has a $20 Billion Hole.” The premise of the article was that the projections of the additional revenue that would be received by limiting the SALT...more

Bradley Arant Boult Cummings LLP

Alabama DOR Grants Extension to Make PTE Tax Election for 2022 Tax Year

In 2021, the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The Alabama Electing...more

Kohrman Jackson & Krantz LLP

So, You Want to Be a Billionaire? Tax Considerations for Winning the Mega Millions Jackpot

As of today, no one has successfully picked the right numbers to win the current Mega Millions. Based on current projections, it is scheduled to reach $1.35 Billion by the drawing on Friday, January 13, 2023. This is the...more

Warner Norcross + Judd

The New Inflation Reduction Act Explained

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Background on Build Back Better- The Build Back Better Act (BBBA) proposed in 2021 was a $1.7 trillion legislative package containing President Joseph Biden’s ambitious plan for targeting social issues and climate change. ...more

Pillsbury Winthrop Shaw Pittman LLP

Senate Democrats Announce Breakthrough Bill on Energy, Climate, Tax Reform and Prescription Drug Pricing

The Inflation Reduction Act of 2022 would constitute a historic investment in the U.S. clean energy industry. If passed, the bill would be the biggest and most significant climate and energy bill ever passed by Congress....more

Sands Anderson PC

Virginia’s New Elective PTE Tax and SALT Cap Workaround

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Elective PTE Income Taxes Payable to Virginia - Beginning July 1, 2022, Virginia’s new law establishing a workaround for the federal income tax limitation on deductions for state and local taxes (SALT) became effective....more

Bradley Arant Boult Cummings LLP

ADOR Grants Extension to Make PTE Tax Election for 2021 Tax Year

Readers may recall that the Alabama Legislature unanimously enacted an elective pass-through entity tax (PTE Tax) last year as a workaround to the so-called “SALT Cap,” which was part of the Tax Cuts and Jobs Act of 2017. The...more

Buckingham, Doolittle & Burroughs, LLC

Ohio Income Tax – Ohio Jumps on Trend to Codify SALT Deduction Cap Workaround

Last year, a post explained that investors in Ohio pass-through entities (PTEs) may be able to avoid the $10,000 state and local tax (SALT) deduction cap using Ohio’s composite return election. Now a little over a year later,...more

Baker Donelson

SALT Select Developments - April 2022

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State and local taxes impact almost every taxpayer, and developments in any one jurisdiction can be frequent and sometimes confusing. In this newsletter edition, we will briefly summarize certain SALT developments in several...more

Williams Mullen

Tax Planning Opportunity for Owners of Pass-Through Entities: Virginia Enacts Workaround to $10,000 Federal Income Tax Limitation...

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Virginia recently enacted legislation that provides an opportunity for the owners of a qualified pass-through entity (PTE) to reduce their federal income tax liability if the PTE makes an election to pay Virginia taxes at the...more

Mitchell, Williams, Selig, Gates & Woodyard,...

Arkansas's Answer to the SALT Cap for Business Owners: The Arkansas Pass-Through Entity Tax Act

The Tax Cuts and Jobs Act of 2017 (The “TCJA”) imposes a $10,000 cap on the amount an individual may deduct for federal tax purposes for the payment of state and local income, property and sales taxes (referred to as “SALT”)....more

Miles & Stockbridge P.C.

And Then There Were Some: Maryland, Virginia, and DC’s Stance on Pass-Through SALT Deduction Workarounds

In late 2020, the IRS issued a notice confirming imminent proposed regulations that would allow certain tax strategies to avoid the individual $10,000 state and local tax (“SALT”) deduction limitation of the Tax Cuts and Jobs...more

Rivkin Radler LLP

New York’s Pass-Through Entity Tax, F Reorgs, and the Sale of An Electing S Corp

Rivkin Radler LLP on

Timing- I had planned to post this piece during the third week of December, a day or so after the exchange between Senator Manchin and the White House sealed the fate of the Build Back Better plan, at least in its current...more

Bradley Arant Boult Cummings LLP

Where Are We On The New Elective PTE Tax Regime?

Earlier this year, Alabama became one of 19 or so states to enact a pass-through entity tax as a workaround to the so-called "SALT Cap" enacted as part of the Tax Cuts and Jobs Act of 2017, which limits the deductibility of...more

Foster Garvey PC

The Oregon SALT Cap Workaround for Pass-Through Entities Is Finally Here – Governor Kate Brown Has Signed Senate Bill 727 Into Law

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Last fall, the IRS announced, with respect to pass-through entities (LLCs or other entities taxed as partnerships or S corporations), that, if state law allows or requires the entity itself to pay state and local taxes (which...more

Rivkin Radler LLP

The 2022 Federal Budget, Including Tax Changes – Are We There Yet?

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It Seemed Like a Good Idea- In July of this year, one of my partners, who chairs the board of a local grantmaking public charity, asked if I would present at a CLE program to be sponsored by the charity on October 28 (last...more

McDermott Will & Emery

[Webinar] Tax in the City® - November 2nd, 11:30 am - 1:00 pm PDT

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Recent tax proposals may bring significant changes to the US federal, international and state and local tax landscape. Join us for our first nationwide Tax in the City® program for a discussion on the key proposed changes...more

ArentFox Schiff

One, Two, Three, Four . . . Can I Have a Little More? Another State Enacts SALT Cap Workaround

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While business owners wait to see whether Congress raises the U.S. long-term capital gains rate from 20 percent to 25 percent and enacts relief from the limitations on the deductibility of state and local taxes (SALT),...more

Rivkin Radler LLP

Gifts, Sales and Effective Dates: The Race Against the Clock the Taxpayer Cannot See

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It was quite a week, wasn’t it?- Manchin- Senator Manchin continued to attract a lot of attention. To the dismay of his fellow Democrats, the West Virginian – who also chairs the Senate Energy and Natural Resources...more

Proskauer - Tax Talks

Tax Provisions of the American Families Plan

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On Wednesday, April 28th, the White House announced the American Families Plan, the “human capital” infrastructure proposal. The American Families Plan would spend $1.8 trillion, including $800 billion in tax cuts over ten...more

Buckingham, Doolittle & Burroughs, LLC

SALT Cap Workaround – Ohio provides PTE investors who elect workaround with income tax benefit.

Individuals are limited to deducting $10,000 ($5,000 for married filing separate) of state and local taxes (SALT) on their Federal income tax. Generally, income earned by pass-through entities (PTE) is taxed at the investor...more

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