Christine Walizer, Author at The S Corporation Association

Preventing a Double Tax

Last month, we outlined why the Joint Committee on Taxation’s interpretation of new Section 68 could subject trust and estate income to an unintended second layer of tax.

Earlier today, S-Corp took the next step, sending the following letter to Treasury’s Office of Tax Policy urging the Department to use its regulatory authority to preserve the longstanding conduit treatment of trusts and estates:

Dear Assistant Secretary Kies:

On behalf of the S Corporation Association, we write to further describe the issue we raised earlier regarding the possible application of the 2/37ths itemized deduction reduction under new IRC Section 68 to the …

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admin2026-07-07T17:45:49+00:00July 7, 2026|

NIIT? Just Say Nyet

Long-time S-Corp ally George Callas is out with a great piece on the history of the NIIT and how the effort to expand the tax to active business income is nothing more than a money grab built on revisionist history. Congress exempted active business income from the NIIT on purpose, and for good reason.

This is a big deal for S corporations. As George explains:

Despite this extensive effort by both Congress and Treasury to limit the NII tax to taxpayers who “lived off investments,” the proponents of higher taxes are now characterizing the exemption of active business income as …

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admin2026-07-02T16:40:10+00:00July 2, 2026|

CTA Catch-22

Yesterday, the House Rules Committee declined to make in order an amendment to the National Defense Authorization Act (NDAA) that would have protected Main Street businesses from the CTA’s burdensome beneficial ownership reporting requirements. The amendment, led by Representatives Warren Davidson and Michelle Fischbach, was ultimately left out of the 312 amendments made in order for floor consideration.

Apparently, Rules was concerned that the amendment was not germane to the defense bill. That’s odd, given the CTA originally became law by riding on the NDAA back in 2020.

The decision also came despite more than 60 trades, including the S Corporation …

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admin2026-06-30T19:49:29+00:00June 30, 2026|

A Tale of Two Studies

The Brookings Institution is out with two new tax studies, one great, one not so much.

The great one is a paper by Bill Gale, Adam Looney and Elena Patel calling for a border-adjusted cash-flow tax. This is something S-Corp supported when it was debated in Congress back in 2016, and it’s still a good idea. Why? It would balance out tax rates between industries and financing methods, it would eliminate the need for all those ridiculous international rules, and it would fit nicely into a corporate integration regime that would level the playing field for close-held businesses …

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admin2026-06-17T20:39:03+00:00June 17, 2026|

SALT Parity State of Play

Lots to report on the SALT Parity front. As you can see from our map, the number of states adopting our PTET elections is up to 38, with only four to go. It’s not all good news, however, as some states are considering backsliding on the policy while others are using the PTET regime to offset significant new taxes. Here’s the rundown.

Back in March we flagged an emerging threat to New York’s Parity regime, noting that their budget proposals included PTET “haircuts” that would siphon money away from New York’s …

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admin2026-06-12T10:02:51+00:00June 12, 2026|