Richard Fox, shareholder in the firm's Tax section, authored a three-part series in Bloomberg Tax's Daily Tax Report, "IRS Final Regulations Deal Fatal Blow to SALT Limitation Workaround," analyzing the regulations and workaround that that high-tax states have attempted regarding the $10,000 annual state and local tax limitation enacted in the 2017 tax law.
- In Part 1, Richard summarizes the background, proposed regulations and final regulations.
- In Part 2, he walks through rejected prior guidance, existing charitable contribution regulations and a safe harbor allowing for deduction for certain payments.
- In Part 3, he explains safe harbors for business deductions not available to individuals.
The full article also ran in Bloomberg as a Tax Management Memorandum and in Bloomberg's Estates, Gifts and Trusts Journal.