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Income Taxes › Pass-Through Entities › Tax Cuts and Jobs Act

Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect... more +
Income taxes are taxes that are collected on the individual earnings of persons or entities. Depending on the jurisdiction, income taxes are calculated and collected in a variety of ways. Some tax systems collect income taxes based on a progressive scheme, while others may utilize a proportional or regressive framework. less -
Latham & Watkins LLP

One Big Beautiful Bill: Key Business and Investment Impacts

Latham & Watkins LLP on

On July 4, 2025, President Trump signed into law H.R. 1, known as the One Big Beautiful Bill Act (the Act). The Act changes key features of US tax law. Notably, the Act: ..Makes permanent the Section 199A2...more

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part IV – The Qualified Business Income Deduction / Code Section...

Foster Garvey PC on

In this fourth installment of my multi-part series on the One Big Beautiful Bill Act (the “Act”), Steve Nofziger and I discuss a provision of the Act that impacts pass-through business entities and their owners, Code Section...more

BakerHostetler

[Podcast] An Analysis of the 2025 Federal Tax Changes Under the “One Big Beautiful Bill” Legislation

BakerHostetler on

The Honorable Peter Roskam, Federal Policy Team Leader, and Jeff Paravano, Tax Group Chair, break down the 2025 tax reconciliation legislation. They explore how the new law preserves key provisions of the Tax Cuts and Jobs...more

Whiteford

Client Alert: The Senate’s Other Big Beautiful Bill – Notable Changes to the House Version

Whiteford on

The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more

Seward & Kissel LLP

House Tax Bill 2025

Seward & Kissel LLP on

On May 12, 2025, Republicans in the House of Representatives introduced the One, Big, Beautiful Bill of 2025 (the “House Bill”). The House Bill comes out of the House Ways and Means Committee after weeks of internal drafting...more

Rivkin Radler LLP

Supreme Court to Decide: No Realization Means No Moore Income Tax?

Rivkin Radler LLP on

Many of you, perhaps most, may have read about a case that will be heard by the U.S. Supreme Court during its current term. The case, Moore v. United States, comes out of the Ninth Circuit Court of Appeals. The Supreme Court...more

Bradley Arant Boult Cummings LLP

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

Bradley Arant Boult Cummings LLP on

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

Eversheds Sutherland (US) LLP

Georgia’s 2023 legislative session ends with significant tax legislation

Eversheds Sutherland (US) LLP on

During the 2023 legislative session, the Georgia General Assembly passed significant tax legislation including decoupling from IRC § 174, imposing sales tax on certain digital goods, and revising eligibility for the...more

J.S. Held

Don’t Double Tax Your Business: How The PTE Tax Can Impact the Valuation of Pass-Through Entities

J.S. Held on

Taxes can have a significant impact on the value of a business. Pass-through entities such as S-Corporations and partnerships generally do not pay any taxes since the income is passed through to the individual shareholder or...more

Bradley Arant Boult Cummings LLP

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

Bradley Arant Boult Cummings LLP on

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

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

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

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

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

Miles & Stockbridge P.C. on

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

Bradley Arant Boult Cummings LLP

Where Are We On The New Elective PTE Tax Regime?

Bradley Arant Boult Cummings LLP on

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

Harris Beach Murtha PLLC

Massachusetts Enacts Pass-Through Entity Tax

Harris Beach Murtha PLLC on

One of the most controversial individual income tax changes enacted under the Tax Cuts and Jobs Act of 2017 is the $10,000 cap on the deduction for state and local income and property taxes (“SALT”) for federal income tax...more

ArentFox Schiff

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

ArentFox Schiff on

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

Bradley Arant Boult Cummings LLP

ADOR Issues Helpful Estimated Tax Guidance on New Elective PTE Tax

Bradley Arant Boult Cummings LLP on

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 that limits the deductibility of...more

McDermott Will & Schulte

Illinois Enacts Pass-Through Entity Tax to Help Partners and S Corporation Shareholders Avoid the $10,000 SALT Cap

McDermott Will & Schulte on

Illinois enacted a pass-through entity tax (PTE Tax) that may be elected by partnerships and S corporations to permit a federal deduction of state income taxes that otherwise are limited to $10,000 per year from 2018 to 2025...more

Cadwalader, Wickersham & Taft LLP

Wyden Proposes Expansion of Pass-Through Deduction

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On July 20, 2021, Senate Finance Committee Chair Ron Wyden (D-OR) proposed legislation to modify the 20% deduction allowed to investors in certain pass-through businesses under Section 199A....more

Sullivan & Worcester

SALT Cap Workaround and Other Tax Provisions in the Pending Massachusetts FY22 Budget

Sullivan & Worcester on

On Friday, July 9, the Massachusetts Legislature voted in favor of the Conference Committee’s revised fiscal year 2022 (FY22) budget bill, House No. 4002[1] (budget bill). The Governor has until Monday, July 19 to either...more

Blank Rome LLP

New York State Enacts Pass-Through Entity Tax as SALT Limitation Workaround

Blank Rome LLP on

On April 19, 2021, New York Governor Andrew Cuomo signed into law legislation that creates a New York Pass-Through Entity Tax, effective for tax years beginning on or after January 1, 2021. This consequential tax legislation,...more

Rivkin Radler LLP

New York Is Getting Out Of The Zone, The Qualified Opportunity Zone, That Is

Rivkin Radler LLP on

New York’s Governor Cuomo is having a bad 2021. Some may attribute this to his hubris or to karma; others may point to an emboldened, and now veto-proof, progressive State Legislature; many will claim that Mr. Cuomo is paying...more

Rivkin Radler LLP

New York Budget Deal Includes SALT Cap Workaround

Rivkin Radler LLP on

The New York state budget deal announced yesterday includes a workaround of the temporary federal limit on state and local tax deductions (the SALT cap). The provision was part of Gov. Cuomo’s initial budget proposal in...more

Burr & Forman

South Carolina May Join Other States to Provide State and Local Tax Cap Workaround

Burr & Forman on

The Tax Cuts and Jobs Act of 2017 (TCJA) imposed a $10,000 cap on the federal deduction for state and local taxes for tax years 2018-2025.  While corporations are not subject to the cap, business owners who pay state and...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

Harris Beach Murtha PLLC

IRS Provides Certainty Regarding Deductibility of Connecticut Pass-Through Entity Tax Payments

Harris Beach Murtha PLLC on

One of the most controversial individual income tax changes enacted under the Tax Cuts and Jobs Act (“TCJA”) is the $10,000 cap on the deduction for state and local income and property taxes (“SALT”) for federal income tax...more

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