SALT Cap Not Unconstitutionally Coercive

A district court has dismissed a lawsuit filed by four states’ against the federal government, ruling that the $10,000 state and local taxes (SALT) federal deduction cap is not unconstitutionally coercive. In 2018, New York, Connecticut, Maryland, and New Jersey filed...

Final Regs Revert Back to Prior Partnership Disguised Sale Rules

New final regulations that address the allocation of partnership liabilities for disguised sale purposes revert back to prior regulations. Under the final regulations: a partner’s share of a recourse liability of the partnership equals the partner’s share of the...

IRS Provides Section 199A Safe Harbor for Rental Real Estate

The IRS has issued a revenue procedure with a safe harbor that allows certain interests in rental real estate to be treated as a trade or business for purposes of the Code Sec. 199A qualified business income (QBI) deduction. The safe harbor is intended to lessen...