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New Legislation Pass-Through Entities

Jackson Walker

One Big Beautiful Bill Act Increases Deduction for State and Local Tax but Fails to Address Nexus Concerns

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In welcome news for individual taxpayers, the One Big Beautiful Bill Act temporarily increases the “SALT cap” – the limit on the amount of the income tax deduction for state and local income, sales, and property taxes – from...more

Venable LLP

SALT Alert: Maryland Fixes PTET for Residents, but S Corporations Face New Risk

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As part of its fiscal 2026 budget legislation (H.B. 352), Maryland enacted a significant change to its elective pass-through entity tax (PTET) regime. Effective for tax years beginning after December 31, 2025, the PTET base...more

Cole Schotz

Salt Provisions In The One Big Beautiful Bill Act: A Mirage Rather Than A Panacea Of Relief For High-Income Earners

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On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (OBBBA) into law ushering in sweeping federal tax changes. The legislation notably expands the Qualified Business Income (QBI) deduction for professionals...more

Miller Canfield

Business Tax Updates in the One Big Beautiful Bill

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The One Big Beautiful Bill creates and/or modifies a number of tax rules that impact taxation of business income, including the permanent extension of the 20% pass-through deduction under Section 199A and the return of full...more

Ropes & Gray LLP

2025 Tax Legislation Update: One Big Beautiful Bill Act Narrowly Passes Senate

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The “One Big Beautiful Bill Act” (the “BBB”) was passed by the U.S. House of Representatives on May 22, 2025 (such version, the “House Bill”) as part of the Republican Congress’s reconciliation package. The BBB generally...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

Cadwalader, Wickersham & Taft LLP

Taxpayers Worked Up About PTET Workarounds

The Senate’s version of the One Big Beautiful Bill Act (the “Act”) was released on June 16th, following the House’s passing of its version of the bill in late May. Among the many tax-related changes in both versions of the...more

Cooley LLP

Proposed Federal Tax Legislation Would Effect Three Key Changes to State and Local Tax Deductibility Limits

Cooley LLP on

On May 22, the House of Representatives passed proposed tax legislation titled, “The One, Big, Beautiful Bill” (TOBBB), which will now be debated in the Senate. Among other proposals, if enacted into law, TOBBB would make...more

Wilson Sonsini Goodrich & Rosati

California Senate and Assembly Budget Agreement Includes Temporary Suspension on Use of California NOLs and Limitations on Use of...

On May 10, 2024, California Governor Gavin Newsom released a revised budget for 2024-2025 that includes, among other changes, a temporary suspension on the use of net operating losses (NOLs) for businesses with California...more

Williams Mullen

Virginia Dept of Tax Issues Clarifying Guidance for Recent Changes to Pass-Through Entity Tax

Williams Mullen on

The General Assembly enacted legislation (H.B. 1456 and S.B. 1476) during its 2023 Regular Session that removed some of the barriers for qualifying for Virginia’s Pass-Through Entity Tax (PTET) election and altered how PTET...more

Williams Mullen

Increased Flexibility for Pass-Through Entity Tax Election Passes Through General Assembly

Williams Mullen on

During its 2023 Session, the Virginia General Assembly passed legislation, H.B. 1456 and S.B. 1476, that removes some of the barriers for participating in Virginia’s elective Pass-Through Entity Tax (PTET)....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

Venable LLP

California Improves Its SALT Cap Work-Around

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California has revised its existing SALT cap work-around to address and liberalize several of the significant limitations on the work-around that we discussed in our prior alert. On February 9, Governor Gavin Newsom signed...more

Miller Canfield

Michigan Pass-Through Entity Tax Enacted - Quick Action May Be Needed for 2021

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Michigan Gov. Gretchen Whitmer signed legislation on December 20, 2021, allowing Michigan pass-through entities to elect to pay a newly enacted 4.25% income tax and for the owners of those entities to claim a tax credit...more

Nutter McClennen & Fish LLP

Overriding the Governor, Massachusetts Legislature Gives Pass-Through Entity Owners a Workaround to Federal SALT Deduction Cap

The Massachusetts legislature, overriding Governor Baker’s prior veto, has voted to enact a new elective pass-through entity (“PTE”) tax designed as a way for PTE owners to get out from under the $10,000 cap ($5,000 for...more

Sheppard Mullin Richter & Hampton LLP

California Passes “Workaround” To Federal Limit on State Tax Deduction For Certain Owners of Pass-Through Entities

On July 16, 2021, Governor Newsom signed California Assembly Bill 150 into law, allowing certain owners of passthrough entities to find a way around the current $10,000 federal cap on state and local tax (SALT) deductions for...more

Bradley Arant Boult Cummings LLP

Congress Passes Corporate Transparency Act Requiring Certain Companies to Report Beneficial Ownership Information

On December 11, 2020, the U.S. Congress passed legislation requiring certain privately held companies in the U.S. to report ownership information to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network...more

Perkins Coie

IRS Announces Delay of Certain Periods for 1031 Transactions

Perkins Coie on

In response to the ongoing coronavirus pandemic (COVID-19), the Internal Revenue Service (the IRS) has taken additional actions intended to provide immediate relief to taxpayers. Delay of Identification and Acquisition...more

Seyfarth Shaw LLP

An Electing Real Property Trade or Business can Revoke its Election on Account of the Change to Qualified Improvement Property...

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On April 10, 2020, the Internal Revenue Service (the “IRS”) issued Revenue Procedure 2020-22 (the “Revenue Procedure”), which (1) permits an “electing real property trade or business” that elected not to be subject to the...more

Flaster Greenberg PC

NJ Passes New Workaround Rule for SALT Deductions

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On January 13, 2020, New Jersey Governor Phil Murphy signed into law the “Pass-Through Business Alternative Income Tax Act” (the Workaround Act). The Workaround Act establishes an elective entity level tax on an individual’s...more

Verrill

Connecticut Reacts to Federal Tax Law Reform Changes

Verrill on

The sweeping changes created by the federal Tax Cuts and Jobs Act (“TCJA”) has resulted in some states enacting their own legislation in response to the federal tax reform. On May 31, 2018, Connecticut signed into law a bill...more

Pullman & Comley, LLC

Are Connecticut Income Taxes Now Tax Deductible For The Owners Of Pass-Through Entities?

Pullman & Comley, LLC on

June 5, 2018 The Tax Cuts and Jobs Act, which was passed by Congress last year, imposed a $10,000 limit on state and local tax (“SALT”) deductions. ...more

Foodman CPAs & Advisors

Make your connection with the “Top 10” Tax Cut and Jobs Act Changes and be prepared for 2019!

Here are the changes from the Tax Cut and Jobs Act (TCJA) that will impact “most” Individuals when they prepare their 2018 Tax Returns in 2019...more

Troutman Pepper Locke

Focus on New Tax Law: Section 199A Pass-Through Deduction and Restrictions on Interest Deductions Tax Update, Volume 2018, Issue 2

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The Tax Cuts and Jobs Act (2017 Tax Act) significantly modified the treatment of certain deductions for many business taxpayers, including partners and partnerships....more

Bradley Arant Boult Cummings LLP

Alabama Legislature Passes Bill to Address Calculation of Credit for Taxes Paid to Other States - State & Local Tax Alert: Alabama...

Gov. Kay Ivey signed House Bill 384, into law last Wednesday, March 28, ending a debate that has lasted for almost a decade over the scope of the individual income tax credit for certain taxes paid to other states. ...more

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