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SALT Implications of the One Big, Beautiful Bill Act

By , and 17 Mins Read

On July 4, 2025, President Donald Trump signed the One Big, Beautiful Bill Act (hereinafter, “OBBBA” or “the Act”) into law. OBBBA enacts sweeping changes to the Internal Revenue Code (“Code”), many of which will impact taxpayers at the state level, including reforms to the federal state and local tax (“SALT”) deduction, Global Intangible Low-Taxed Income (“GILTI”), Foreign-Derived Intangible Income (“FDII”), section 174 research and development expensing, and section 163(j) business interest deduction limitations. Notably,…

States’ Conformity with Proposed Federal Border Adjustment Tax May Result in Violation of the Foreign Commerce Clause of the US Constitution

By 4 Mins Read

President Trump and Congressional Republicans appear eager to move onto federal tax reform given their recent failed attempt to repeal and replace the Affordable Care Act. But, enacting the first major overhaul to the Internal Revenue Code since the Tax Reform Act of 1986 will be no small task, especially considering that the proposed legislation greatly differs in its effects on corporate taxpayers.