State Tax Credit Issues Raised By SALT Cap Workaround Legislation
99 Tax Notes State 211
10 Pages Posted: 9 Mar 2021
Date Written: March 7, 2021
The IRS’s notice recognizing the deductibility of state passthrough entity taxes for federal personal income tax purposes has already spawned considerable interest regarding the issues raised by those levies for state tax purposes. Among these issues is the ability of PTE owners to claim a credit against their personal income tax liability in their state of residence for their distributive share of entity level taxes paid to other states where the income was earned. This article addresses the relevant issues in light of the underlying constitutional and policy concerns.
Keywords: tax, workaround, state, local, federal, passthrough, entity, pte, ubt, unincorporated, salt cap
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