SALT-Free Alchemy? Converting State Taxes to Charitable Deductions
In his Estate Planning and Philanthropy column, Conrad Teitell writes: “The Tax Cuts and Jobs Act,” Pub. L. No. 115-97, limits an individual's deduction under IRC Section 164 for the total amount of state and local taxes (SALT) paid during the calendar year to $10,000 ($5,000 for a married individual filing a separate return)
June 22, 2018 at 01:57 PM
1 minute read
|
State Law Workarounds
|New York's Legislation to Avoid the SALT Limitation—In Brief
|Another New York Workaround
|If You Can Deduct It Here, Can You Deduct It Anywhere?
- IRS warning in Notice 2018-59 (5/23/18)
- Guidance to be issued
- Translation
- Dear Latin scholar readers
- Drafting information
- Timetable for proposed regulations?
- Arguments for allowing charitable deductions for the SALT workarounds.
On the other hand:
- IRS memos lack the authority of revenue rulings and regulations.
- The IRS memos were released when there wasn't a federal cap on deductibility of state and local taxes.
- “I think it's absolutely appropriate for Treasury to signal that these are tax evasion schemes, and it's good for them to signal that early on,” House Ways and Means Chairman Kevin Brady of Texas.
Parthian Shot
Conrad Teitell is a principal at Cummings & Lockwood in Stamford, Conn.
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