The Tax Cuts and Jobs Act (the Act)1 is the most far-reaching change to the Internal Revenue Code in over 30 years. Among other significant changes is the elimination or limitation until 2026 of most itemized deductions that had been allowed for individuals for federal income tax purposes. Although the state and local tax (SALT) deductions weren’t eliminated, the Act places an annual $10,000 limit on them under new IRC Section 164(b)(6). This new limitation has prompted certain states (and, in some cases, their political subdivisions) that impose high taxes to consider legislative proposals that would allow their residents to avoid the new $10,000 annual deduction limitation or curb its impact.
Proposals being considered by at least three...
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