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,…
In response to the federal $10,000 cap on the state and local tax deduction, New Jersey recently enacted an elective pass-through entity tax. By taxing pass-through entities, the law shifts the tax burden from individuals subject to the federal deduction limitation to entities that are not subject to the limitation, which deduction then flows through to the pass-through entities’ owners without limitation. While uncertainty remains about the federal deductibility of such state pass-through entity taxes by individual owners, New Jersey joins a growing number of states to pass similar legislation in the wake of the SALT deduction cap, including Connecticut, Louisiana, Oklahoma, Rhode Island, and Wisconsin.