The Proposed SALT Regulations May Be Doomed

103 Iowa Law Review Online 75 (2018)

13 Pages Posted: 13 Oct 2018 Last revised: 21 Oct 2018

See all articles by Andy Grewal

Andy Grewal

University of Iowa - College of Law

Date Written: September 20, 2018

Abstract

The IRS recently followed through on its promise to address state strategies designed to avoid the new state & local tax deduction limits. Although programs adopted by blue states sparked the IRS’s interest, the proposed regulations address both blue and red state programs. This has, predictably, led to IRS criticism from all sides. But the IRS was right to step in here. Revenue and policy concerns easily justify administrative guidance on the state strategies.

Unfortunately, the proposed regulations suffer from some significant technical and conceptual flaws. Those flaws, if left unaddressed, may jeopardize the validity of any final regulations, especially as they apply to red state programs. This essay discusses the flaws in the proposed regulations and offers recommendations for improvement.

Suggested Citation

Grewal, Amandeep S., The Proposed SALT Regulations May Be Doomed (September 20, 2018). 103 Iowa Law Review Online 75 (2018). Available at SSRN: https://ssrn.com/abstract=3252134

Amandeep S. Grewal (Contact Author)

University of Iowa - College of Law ( email )

Melrose and Byington
Iowa City, IA 52242
United States

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