Bradley Partner Bruce Ely Quoted in Law360 on Confusion Regarding SALT Workarounds

Bradley attorney Bruce Ely was quoted in Law360 on a “clarification” issued by the U.S. Department of the Treasury and the Internal Revenue Service that has still left many tax professionals confused about state and local tax deduction workaround regulations.

Ely said he also found the clarification troubling. But as counsel for several groups that grant scholarships for private school tuition, he had another take on the issue.

The clarification was an attempt by Treasury and the IRS “to save their proposed regs on charitable contributions,” he said. “But I fear that in their attempt, they may have caused even more concern.” 

“Neither document mentioned the alternative deduction under Section 164,” Ely said. “Why didn’t Treasury mention that alternative, which many companies currently rely on as the basis for their deduction of these donations?”

The complete article, “IRS Notice On SALT Workarounds Causes More Confusion,” appeared in Law360 on September 6, 2018.