Abstract
In November 2020, after the election was over, in form at least, the Treasury and the IRS issued Notice 2020-75, announcing that proposed regulations will be issued governing the treatment of new state laws that impose income taxes on what are passthrough entities for federal income tax purposes. Those laws are clearly intended to provide a way to circumvent the cap on the deductibility of state and local taxes (SALT) included in the Tax Cuts and Jobs Act of 2017, and the Notice is very taxpayer friendly in its understanding of these arrangements. This article considers the particulars and the implications of the Notice.
Keywords
Notice 2020-75, SALT deduction cap, IRC Section 164
Publication Date
2021
Document Type
Article
Publication Information
Journal of Taxation of Investments, Winter 2021, at 75
Repository Citation
Jensen, Erik M., "A SALT Cap Workaround That Works? Notice 2020-75" (2021). Faculty Publications. 2338.
https://scholarlycommons.law.case.edu/faculty_publications/2338
