Whether Congress's imposition of a $10,000 cap on the SALT deduction violates Article I, Section 8 and the Tenth and Sixteenth Amendments of the United States Constitution

QUESTION PRESENTED From the time of the first federal income tax in 1861, Congress has respected the States’ sovereign authority to levy and collect taxes by providing for a deduction of all or substantially all state and local property and income taxes (“SALT”) from federal taxable income. In 2017, Congress severely curtailed the SALT deduction for the first time in history. The 2017 tax legislation allows an individual to deduct a maximum of $10,000 of state and local taxes, regardless of that taxpayer’s actual state and local tax burden. The question presented is: Whether Congress’s imposition of a $10,000 cap on the SALT deduction violates Article I, Section 8 and the Tenth and Sixteenth Amendments of the United States Constitution.