News & Analysis as of

U.S. Treasury SALT

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

Mintz - ML Strategies

House Democrats Weigh Major Tax Changes for Businesses, Funds, and Individuals

Mintz - ML Strategies on

In May 2021, President Biden’s administration released a $6 trillion budget proposal for the coming fiscal year (Budget), including $3.6 trillion of tax increases over 10 years and generous tax credits to incentivize clean...more

BakerHostetler

Did the IRS Bless the Passthrough Entity Workaround to the $10K SALT Cap?

BakerHostetler on

For three years, states and taxpayers have been looking for novel ways to get around the federal TCJA's $10,000 cap on deducting state and local taxes. The IRS just released Notice 2020-75, which appears to bless states'...more

Cole Schotz

SALT CAP Workaround – An IRS Holiday Gift

Cole Schotz on

The 2017 Tax Act made life harder on individuals living in high tax states (such as New York, New Jersey, and California) by limiting the deduction for state and local taxes (“SALT”) to $10,000. In an attempt to circumvent...more

Ballard Spahr LLP

Treasury Announces Pass-Through Entities Will Not Be Subject to SALT Deduction Cap

Ballard Spahr LLP on

In a surprising—but taxpayer-friendly—development, Treasury announced in Notice 2020-75 (available here) that it will be issuing proposed regulations that allow partnerships and S corporations to deduct certain state and...more

Lowndes

New Treasury and IRS Regulations Bless SALT Deductions for Pass-through Entities

Lowndes on

Monday, the U.S. Department of the Treasury and Internal Revenue Service (IRS) issued a press release and related notice regarding proposed regulations which clarify that the $10,000 cap on state and local tax (SALT)...more

Bradley Arant Boult Cummings LLP

IRS Provides Additional Clarity Regarding Donations to Scholarship Granting Organizations - SALT Alert: Alabama Edition

On December 16, the Internal Revenue Service (IRS) and the Treasury Department issued proposed regulations... that provide some good news and needed clarification for C corporations, individuals, and S corporations and other...more

Bradley Arant Boult Cummings LLP

A More Viable SALT Cap Workaround? Pass-Through Entity-Level Taxes - Bloomberg Tax

Now that the Treasury Department and Internal Revenue Service have issued ?nal regulations to address at least some variations of so-called ‘‘SALT cap workarounds’’ to the Tax Cuts and Jobs Act’s limitation on individual...more

Bradley Arant Boult Cummings LLP

Treasury Department Issues Final Regulations Limiting Charitable Deductions – Potential Impact on Alabama Donors? - SALT Alert:...

Now that the dust has settled following the issuance of the final “SALT cap workaround” regulations by the Treasury Department, here’s a summary of those regulations, the IRS guidance issued in connection with the final...more

BCLP

New Regulations for Charitable Contributions in Exchange for State or Local Tax Credits

BCLP on

The IRS has issued final regulations that address the question of whether a state or local tax credit should be treated as a return benefit, or quid pro quo, when received in return for making a charitable contribution. Under...more

Williams Mullen

IRS Delivers Major Blow to Virginia’s Land Preservation Program

Williams Mullen on

On June 11, 2019, the IRS and U.S. Department of Treasury issued final regulations requiring taxpayers to reduce their charitable contribution deduction by the amount of any state or local tax credits received (or expected to...more

Bradley Arant Boult Cummings LLP

Status Report on IRS Guidance Limiting Charitable Contribution Deductions to Scholarship Granting Organizations - SALT Alert:...

Sometimes the law of unintended consequences is difficult to correct after the fact. The most recent example may be the 2017 Tax Cuts and Jobs Act’s $10,000 annual limitation on state and local tax deductions claimed by...more

Brownstein Hyatt Farber Schreck

Treasury Releases Guidance on Permissibility of State Legislation to Circumvent SALT Deduction Cap

On Aug. 23, 2018, the Department of the Treasury (Treasury) and the Internal Revenue Service (IRS) issued proposed regulations under Section 170 of the Internal Revenue Code (Code) addressing the federal income tax treatment...more

Harris Beach PLLC

New York State among Four States to Sue Federal Government over State and Local Taxes

Harris Beach PLLC on

Earlier today July 17, 2018 New York State was among four states to sue the federal government over State and Local Tax (SALT) deductions being capped at $10,000 as part of recent federal tax law changes. Joining New York in...more

Eversheds Sutherland (US) LLP

IRS to crackdown on SALT deduction Cap workarounds

On May 23, 2018, the IRS and the Treasury Department issued Notice 2018-54 announcing their intention to propose regulations addressing the federal tax treatment of state workarounds to the $10,000 ($5,000 in the case of...more

McDermott Will & Emery

SALT Implications of Proposed Section 385 Debt/Equity Regulations

McDermott Will & Emery on

Determining the difference between debt and equity is a problem that has bedeviled taxpayers and tax administrators for decades. Taxpayers, recognizing that there are tax advantages to financing a corporation with debt (e.g.,...more

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