Since the enactment of the Tax Cuts and Jobs Act (TCJA), an individual’s federal tax deduction for state and local taxes (SALT) paid during the calendar year is limited to $10,000. The SALT limitation impacted many individual partners and shareholders. Several states responded to this limitation by issuing workarounds to enact entity-level taxes for pass-through entities where the entity pays the tax instead of its owners and then deducts the full amount of state taxes paid, thus avoiding the $10,000 limitation at the individual level. It was uncertain whether the IRS would accept this entity-level tax workaround.