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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,…

New Year, Same New York—Bill Proposes Significant Tax Increases for Corporations

By , and 5 Mins Read

Starting the new year off with legislation aimed directly at the pockets of corporate taxpayers, New York has issued a legislative proposal to nearly cut in half corporate taxpayers’ available GILTI exemptions, and at the same time almost double the top corporate franchise tax rate. Senate Bill 953 (“SB953”), pre-filed in the state senate on January 8, 2025, has the potential to significantly increase New York franchise tax exposure for corporations doing business in the…

Nebraska Supreme Court Affirms Denial of “Deemed Dividend” Deduction For IRC §965 Income

By and 4 Mins Read

The one-time IRC §965 income inclusion for untaxed foreign earnings generated by a controlled foreign corporation (“CFC”) is not eligible for deduction from Nebraska taxable income as a “deemed dividend” according to a recent Nebraska Supreme Court decision, Precision Castparts Corp. v Nebraska Dept. of Revenue, 317 Neb. 481 (2024). Precision Castparts Corp. (“Taxpayer”), an aerospace component manufacturer, sought a declaratory order from the Nebraska Department of Revenue (“Department”) authorizing the company to amend its…

Coronavirus Relief Bill Attempts to Address SALT Matters for Telecommuting Employees

By and 3 Mins Read

On Monday, July 27, the Senate Finance Committee released draft legislative provisions (“COVID-19 Bill”) regarding the next iteration of Coronavirus relief.  Somewhat surprisingly, the provisions include the Remote and Mobile Worker Relief Act of 2020, which was introduced earlier this year as S. 3995 by Sens. Sherrod Brown (D-OH) and Jon Thune (R-SD). S. 3995 appears to be based on S. 604, the Mobile Workforce State Income Tax Simplification Act (“Mobile Workforce Act”), which was…

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