Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 2 of 2
Full-Text Articles in Taxation
Dual Residents: A Sur-Reply To Zelinsky, Michael S. Knoll, Ruth Mason
Dual Residents: A Sur-Reply To Zelinsky, Michael S. Knoll, Ruth Mason
All Faculty Scholarship
In this article, we respond to Professor Zelinsky’s criticism of our arguments regarding the constitutionality of New York’s tax residence rule. We argue that the Supreme Court’s decision in Wynne requires reconsideration of the New York Court of Appeal’s decision in Tamagni.
On The Disparate Treatment Of Business And Personal Salt Payments, Michael S. Knoll
On The Disparate Treatment Of Business And Personal Salt Payments, Michael S. Knoll
All Faculty Scholarship
The Tax Cuts and Jobs Act, H.R. 1, would eliminate the federal income tax deduction for nonbusiness state and local taxes while maintaining the deduction for business state and local taxes. That disparate treatment has generated a storm of negative commentary. In this short essay, I consider whether the federal tax law should allow a deduction for business state and local taxes assuming that there is no deduction for nonbusiness state and local taxes. I argue that investors and businesses, including pass-through businesses, should be allowed to deduct state and local property and sales taxes, but not general income taxes.