State Tax Credit Issues Raised By SALT Cap Workaround Legislation

99 Tax Notes State 211

10 Pages Posted: 9 Mar 2021

See all articles by Walter Hellerstein

Walter Hellerstein

University of Georgia School of Law

Andrew D. Appleby

Stetson University College of Law

Date Written: March 7, 2021

Abstract

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

Suggested Citation

Hellerstein, Walter and Appleby, Andrew D., State Tax Credit Issues Raised By SALT Cap Workaround Legislation (March 7, 2021). 99 Tax Notes State 211, Available at SSRN: https://ssrn.com/abstract=3799584

Walter Hellerstein

University of Georgia School of Law ( email )

209 Hirsch Hall
Athens, GA 30602
(706) 542-5175 (Phone)
(706) 542-5556 (Fax)

Andrew D. Appleby (Contact Author)

Stetson University College of Law ( email )

1401 61st Street South
Gulfport, FL 33707
United States
727.562.7327 (Phone)

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