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2025-08-18 State Tax Credit SALT Workaround Regulation Challenge Fails

2025-08-18 State Tax Credit SALT Workaround Regulation Challenge Fails

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This week we look at:

  • Denham Outlines Its Criticisms of the Tax Court’s Use of the Functional Analysis Test for Limited Partners with the First Circuit Court of Appeals
  • Disguised Sales and Sham Partnerships: A Comprehensive Review of PICCIRC, LLC v. Commissioner
  • Judicial Examination of State Charitable Tax Credit Programs and Federal Deductibility
  • The Second Circuit Clarifies Tax Court Filing Deadlines: Implications for Practitioners
  • Understanding New Clean Electricity Credit Termination Rules Impact of IRS Notice 2025-42 on Wind and Solar Facilities

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