NY Proposal Tries to Make Clawback Tax Deductible—But Will the IRS Agree? By Gerry W. Beyer April 24, 2025 Email this postTweet this postLike this postShare this post on LinkedIn New York’s proposed amendment to Tax Law § 954(a)(3), included as Part T in the State Senate’s One-House Budget Bill (S.3009-B), tries something bold: It seeks to recharacterize part of the state estate tax as a deductible debt. Specifically, the…