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Noonan’s Notes Blog

About This Blog

Noonan’s Notes Blog is written by a team of Hodgson Russ tax attorneys led by the blog’s namesake, Tim Noonan. Noonan’s Notes Blog regularly provides analysis of and commentary on developments in the world of New York and multistate tax law. Noonan's Notes Blog is a winner of CreditDonkey's Best Tax Blogs Award 2017.

Contributors

Timothy Noonan 
Ariele Doolittle
Joseph Endres
Daniel Kelly
Elizabeth Pascal 
Craig Reilly
Andrew Wright 

Photo of Noonan’s Notes Blog Joseph R. Rekrut
Associate
jrekrut@hodgsonruss.com
716.848.1715
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Joe is an associate in the firm’s Business and International Tax practice, where he advises businesses, individuals, and non-profit organizations on tax-related …

Showing 2 posts by Joseph R. Rekrut.

Change on the Horizon? - New York Budget Bill Proposes Pass-Through Entity SALT Cap Workaround

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On January 19, 2021, New York Governor Andrew Cuomo published his Fiscal Year 2022 Executive Budget and related legislation (the “Budget Proposal”).  While the Budget Proposal contains a variety of important provisions, this post will cover one of the most notable: the proposed pass-through entity (“PTE”) workaround to the $10,000 limitation on Federal state and local tax deductions (the “SALT cap”).

Clarity at Last – IRS Indicates Forthcoming Approval of SALT Cap Pass-Through Entity Workarounds

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On November 9, 2020, the IRS issued Notice 2020-75 (the “Notice”) informing taxpayers that forthcoming proposed regulations would clarify that state and local income taxes imposed on and paid by a partnership or S corporation (a “pass-through entity” or “PTE”) on its income are allowed as a deduction by the PTE in computing its non-separately stated taxable income or loss for the year of the payment, meaning that such payments are not taken into account in applying the State and local tax (“SALT”) cap limitation to any individual who is a partner of shareholder in the PTE.

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