Too Much SALT: Rejecting the Pass-Through Entity Tax as a SALT Deduction Cap Workaround

Historically, U.S. taxpayers have been able to deduct their state and local taxes from their federal taxable income. This changed with the passage of the Tax Cuts and Jobs Act of 2017, which introduced a $10,000 cap on the state and local tax (SALT) deduction. States have reacted by turning to various methods to mitigate the negative tax consequences of the cap for their residents, including workarounds that use the charitable contribution deduction or a payroll tax as a means to allow full deductibility of state and local taxes. With the IRS striking down the charitable contribution workaround, and the payroll tax workaround being difficult to implement, the latest development has been a pass-through entity workaround. Generally, the pass-through entity workaround allows pass-through entities to pay their income tax at the entity level. The owners of the entity then report their pro rata share of the entity\u27s income on their individual state tax return. Finally, the state provides each owner with a tax credit equal to that amount of taxes. The tax benefit for the owners is that the tax paid at the entity level is deductible a business expense, meaning it is not subject to the SALT cap. Thus, the owners are able to deduct the full amount of state and local taxes that they pay. The Internal Revenue Service issued Notice 2020-75 on Nov. 9, 2020, which suggested that forthcoming regulations would permit the pass-through entity workaround. But it has now been over two years since this Notice was issued under the Trump administration, and there have been no developments on this front under the Biden administration. This Note argues that the Internal Revenue Service should instead issue regulations denying the validity of state legislation allowing for the pass-through entity workaround. In doing so, this Note examines the legislative history of the SALT deduction, compares the pass-through entity workaround to the charitable contribution and payroll tax workarounds, and analyzes public policy arguments for and against the workaround. Ultimately, it concludes that the workaround raises public policy and substance-over-form concerns and that the Treasury Department and IRS should issue regulations disallowing it

Indirect estimation of parameters in a flexible tube, pulsatile flow system

A mathematical model of pulsatile flow and pressure in a flexible tube with a possible branch and stenosis, or constriction, was formulated. Solution of the model equations was performed by the finite element method and a numerical integration procedure. An in vitro experimental model of pulsatile flow in a flexible tube with a stenosis and a branch was devised to provide observed waveforms and directly measured vessel parameter values. The model response satisfactorily matched the experimental data and exhibited sensitivity to the parameters of interest: vessel compliance, peripheral resistance, and severity and location of the stenosis. The model response was not sensitive to the vessel radius;The Gauss-Newton algorithm was used to minimize the sum of squared error between model response and experimental waveforms by varying the model parameters. Validation of the parameter estimation technique was performed by solving the model equations with measured values assumed for the system parameters and using the resulting waveforms in place of measured data. The vessel radius could not be estimated due to lack of sensitivity. The remaining parameters of interest could be reliably estimated except in the case of a mild stenosis, for which the stenosis location could not be estimated

Model-Based Characterization of Planar and Focused Immersion Ultrasonic Transducers

Advanced ultrasonic nondestructive evaluation techniques require well characterized transducers. This need may arise, for example, because modern, cost-efficient fabrication procedures necessitate high reliability inspection through non-planar surfaces and for which careful control of the beam pattern in needed. An example of this is the developing procedure for inspection of titanium billet material for subtle flaws, such as hard-alpha inclusions [1]. Large aperture, bicylindrical focusing transducers are being developed, and characterization procedures are also being formulated for that activity. Methods are required to relate design parameters, such as crystal and lens shape, to the ultrasonic fields that will be generated in the billet. Advanced signal processing methods, such as characterization of noise due to ultrasonic scattering from grains, require precise knowledge of probe characteristics, as well. For example, model-based approaches to calculating a grain scattering “figure of merit” [2] require the ability to deconvolve transducer effects from measured noise signals. Knowledge of transducer characteristics is also essential for the application of ultrasonic measurement models [3,4] to the prediction of flaw signal amplitudes as measured through curved component surfaces and in a variety of materials. This geometry and material transferrability issue is of great importance in new methods applied to designing for inspectability

A Cord of Three: A Phenomenological Study of Linkages in Interdenominational Interactions in Northwest Wyoming as Informed Through Network and Social Exchange Theories

This study explores pastors’ interactions in a rural regional network through Network and Social Exchange Theories. With the increasing need to understand the life experiences of network actors, a qualitative based approach is utilized. The results provide in-depth and contextually sensitive results that traditional quantitative-based techniques cannot. Open-ended interviewing allowed the participants to share their lived experiences, identifying the rhythms of boundary spanning behaviors. This offers hope for those seeking to understand the intricacies that orchestrate groups of people coming together in synergistic relationships. From a biblical understanding, a Cord of Three is not easily broken, and this study reveals multifarious threads (or themes) and the conditions in which these threads readily entwine. As knots can be studied to understand their composition, so can these ties and intersections. The overarching theory for this study is Network Theory, with Social Exchange Theory providing insight into the personal linkages. These two key typologies are used for data interpretation; Eisenberg (2006) helps us understand the Institutional and Representative linkages through a network theory perspective. The institutional level themes centered around syncretism factors and how ecumenical or unity minded the organizations found themselves. At a representative level, resource poverty theory presented findings that showed interactions centering on time efficiencies, human capital needs, and the impact of space scarcity. Salzer’s (1998) typology helps delve into Social Exchange elements and the more personal, intimate factors involving an individual’s discrete setting, organizational and ideological ties, the dynamic of trust, and how common threat acts as a unifier. Patterns and rhythms emerged from the participants\u27 lived stories regarding their respective churches and interdenominational relationships. Interestingly, once certain thresholds are met (such as time demands, theological beliefs, and trust is developed) people are readily willing to cross traditional boundaries and join forces. Individuals can use time, purpose, and trust-building to create powerful personal relationships. Busy schedules and responsibilities hinder many relationships from developing into a healthy regional network, but careful and deliberate attempts to work around these boundaries can bring results. The pastors in this study exhibit that a healthy network can exist in a region, but relationships require effort to maintain and grow. The lived experiences of these pastors show that they are engaging in risky social behavior by trusting their peers in these relationships, but the narratives repeatedly show that the risk is worth the gain. The perspective and social currency gained from these interactions act as a life-giving source when done without ulterior motives. Looking for commonalities and following the rhythms produces opportunities for authentic relationships interactions

Student Recital: Timothy B. Gray, Euphonium

Kemp Recital Hall Saturday Afternoon December 4, 1993 3:00p.m

Ultrasonic Sizing of Cracks in Web Geometries

Evaluation of the critical nature of interior cracks in turbine rotor component web regions in order to assess the remaining service life of the parts requires accurate determination of the crack sizes in order to perform fracture mechanics analysis. This analysis is important both in order to retire critically defective parts and in order to return components to service if detected flaws are sub-critical. The purpose of this paper is to evaluate several techniques for sizing internal cracks in planar geometries

A "no-biopsy" approach to diagnosing celiac disease

Deputy Editor: Katherine Hale, PharmD, BCPS (Kadlec Regional Medical Center)This noninvasive alternative to the diagnostic gold standard may cut risk and expense for adult patients.Timothy Mott, MD; Carrie Gray, DO; Jon Storey, MD (South Baldwin Regional Medical Center Family Medicine Residency Program). Deputy Editor: Katherine Hale, PharmD, BCPS (Kadlec Regional Medical Center)Includes bibliographical reference