News & Analysis as of

Tax Cuts and Jobs Act SALT State Taxes

Venable LLP

SALT Alert: Final OBBBA Temporarily Expands SALT Cap and Revises AMT Phaseout

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The One Big Beautiful Bill Act (OBBBA or the Act), enacted in July 2025, introduces significant changes to the treatment of state and local tax (SALT) deduction and the alternative minimum tax (AMT). ...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

Foster Garvey PC

One Big Beautiful Bill Act, H.R. 1 – 119th Congress (2025-2026): Part I – The SALT Deduction

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On July 1, 2025, the One Big Beautiful Bill Act, H.R.1 – 199th Congress (2025-2026) (the “Act”) was passed in the U.S. Senate (“Senate”). On July 3, 2025, it was passed in the U.S. House of Representatives (“House”) and...more

Cadwalader, Wickersham & Taft LLP

The Senate Lowballs SALT Cap in Its Budget Bill

On June 16, 2025, the U.S. Senate released its version of the budget reconciliation bill (“Senate bill”), making several changes to the House-passed version from May 22, 2025 (“House bill”). One major difference is the cap on...more

Kilpatrick

5 Key Takeaways | SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions

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Kilpatrick’s David Hughes and Jeff Reed recently participated in panel, sponsored by Strafford, addressing the topic of “SALT and Multinational Businesses: Analyzing State and Local Taxation of Foreign Company Transactions.”...more

Skadden, Arps, Slate, Meagher & Flom LLP

The One Big Beautiful Bill Act: An Initial Analysis of Key Tax Proposals

On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more

A&O Shearman

Summary of key provisions in House reconciliation bill

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On May 22, 2025, the U.S. House of Representatives narrowly passed the House budget reconciliation bill (H.R. 1) (the “House Bill”) by a party-line vote of 215 – 214. The House Bill, which includes significant tax law...more

Foster Garvey PC

The House Passes a Tax Bill Containing a SALT Cap Compromise That Is Slightly Better Than Its Prior Proposal

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As reported on May 16, 2025, the SALT cap proposal contained in the legislation that was pending in the U.S. House of Representatives (“House”) aimed at, among other things, dealing with the expiring provisions of the Tax...more

Seward & Kissel LLP

State Taxes: What to Expect in 2025

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A changing tax landscape is on the horizon for the new year. Many of the provisions of the 2017 Tax Cuts and Jobs Act (“TCJA”) are scheduled to expire at the end of the year. President-elect Trump has also proposed a variety...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

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

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

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

Harris Beach Murtha PLLC

Massachusetts Enacts Pass-Through Entity Tax

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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

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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

Dickinson Wright

The SALT Cap and State Taxation of Pass-Through Entities

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Among the many significant changes in the 2017 Tax Cut and Jobs Act (TCJA), individual taxpayers’ deductions for state and local taxes (SALT deductions) on federal Form 1040 Schedule A were capped at $10,000 ($5,000 for...more

Sullivan & Worcester

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

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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

Rivkin Radler LLP

New York Budget Deal Includes SALT Cap Workaround

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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

Bilzin Sumberg

Moving to the Sunshine State: Change of Domicile Planning Considerations

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Florida has long been known as a hot-spot for retirees and snowbirds to move for its sunny weather and beautiful beaches. In recent years, however, since the "SALT Deduction Cap" established by the 2017 Tax Cuts and Jobs Act...more

Freeman Law

Why State And Local Tax Due Diligence Is Important

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Why is State and Local Tax (SALT) due diligence important in mergers and acquisitions?  Someone else’s issues may be your headache and cost you a lot of money!...more

Sullivan & Worcester

Key Tax Provisions in the Massachusetts FY21 Budget

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On December 11, 2020, Massachusetts Governor Charlie Baker signed the Commonwealth’s FY21 budget into law. While the $45.9 billion budget does not raise taxes, it includes a number of significant tax provisions summarized...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

Fox Rothschild LLP

Partnerships And S Corporations Exempted From Limits On State And Local Tax Deduction

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The IRS intends to issue proposed regulations to permit a partnership or an S corporation to deduct specified income tax payments made to a domestic state or local jurisdiction. In Notice 2020-75, the IRS clarifies that...more

Bradley Arant Boult Cummings LLP

Legislative Task Force on the Impact of the Tax Cuts and Jobs Act Releases Its Final Report - SALT Alert: Alabama Edition

The Alabama Legislature was stymied last year over proposals to decouple from or conform with various provisions of the Tax Cuts and Jobs Act of 2017 (TCJA). As a compromise, the Legislature formed a Joint Legislative Task...more

Bradley Arant Boult Cummings LLP

Business Council of Alabama and Birmingham Business Alliance Announce Their 2020 Tax/Economic Development Legislative Agendas -...

The influential Business Council of Alabama (BCA), founded in 1985, and the Birmingham Business Alliance (BBA), the state’s oldest and largest chamber of commerce, have each officially approved their 2020 legislative agendas....more

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