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

This podcast episode of Current Federal Tax Developments, dated August 18th, 2025, covers several key tax-related updates. The host discusses the Denim case concerning self-employment tax and the Functional Analysis Test for Limited Partners, highlighting the taxpayer's brief with the First Circuit Court of Appeals. Also reviewed is the PICCIRC LLC versus Commissioner case, which involves a disguised sale and partnership tax shelter that was struck down in the Second Circuit Court of Appeals. The host analyzes the Second Circuit's decision against New Jersey and New York's attempt to overturn IRS regulations on Charitable Contribution SALT Workarounds. Additionally, the podcast addresses the Second Circuit's ruling on equitable tolling for the tax court's 90-day rule for deficiency petitions and the IRS Notice 2025-42 regarding Clean Energy Credit Termination Rules and beginning of construction, with a focus on the implications for wind and solar facilities.