But it takes away the benefit of the SALT deduction in a nontransparent way that was really never intended by the drafters of the AMT back in 1978. I was on the staff then; I was involved in drafting. Nobody gave any thought to the SALT deduction. There's the workarounds tha...
which held that the gross amount of dividends received from foreign affiliates outside its water’s-edge group should be included in its sales factor denominator, regardless of the application of a dividends-received deduction excluding 75% of such dividends from its taxable base. ...