Maximizing Tax Efficiency: SALT Deductions and Passthrough Entities

The State and Local Tax (SALT) deduction has historically been a key component of the tax code, enabling taxpayers to mitigate the impact of double taxation. This deduction allows taxpayers who itemize to deduct their state and local income or sales taxes alongside property taxes on their federal income tax returns.

Before the TCJA Cap

Prior to the Tax Cuts and Jobs Act (TCJA) of 2017, there was no limit on the SALT deduction, allowing taxpayers from high-tax states—such as New York, California, and Illinois—to deduct full state and local tax payments on their federal returns. However, the introduction of the TCJA imposed a $10,000 cap on SALT deductions for both single filers and married couples filing jointly, and $5,000 for married individuals filing separately. This cap severely impacted residents of high-tax states, where state and local taxes typically exceed the federal threshold.

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New Relief Under OBBBA

The "One Big Beautiful Bill Act" (OBBBA) recently brought relief, with an increased cap commencing in 2025. The new limit starts at $40,000 and rises by 1% each year until it reaches its peak in 2029. After 2029, unless Congress takes further action, the cap will revert to $10,000. This change responds to widespread dissatisfaction among Congress members from high-tax states, offering expanded relief to itemizing taxpayers in these regions.

SALT DEDUCTION CAP

Year

SALT Cap

2024

$10,000

2025

$40,000

½ those amounts for married couples filing separately

Income-Based Limitations

The OBBBA introduces a phase-out of the SALT deduction for higher-income earners, based on modified adjusted gross income (MAGI). Starting in 2025, taxpayers with a MAGI over $500,000 will experience a reduction. Those earning $600,000 or more will see their deduction limited to $10,000, minimizing the impact of the increased cap.

SALT DEDUCTION REDUCTION

Year

MAGI Phase Out Threshold

MAGI - Reduced to $10,000

2025

$500,000

$600,000

2026

$505,000

$606,333

Illustrative Examples

  • Example #1 (2027): A taxpayer with a MAGI of $523,000 will see a deductible reduction, leading to a SALT allowance of $36,919.

  • Example #2 (Maximum Reduction in 2027): For a MAGI of $615,000, the SALT deduction reduces to $10,000.

Exploitation of Passthrough Entities

States have introduced passthrough entity tax (PTET) solutions to counter the federal SALT cap, allowing S corporations and partnerships to remit state taxes at the entity level. By this design, the business itself claims the deduction for state taxes on the federal return. Individual owners benefit from tax credits at the state level, circumventing the SALT cap. This method remains a strategic option for tax efficiency amidst federal limitations, particularly for high-tax states.

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Final Thoughts

The evolution of SALT deductions, spurred by recent legislation such as the OBBBA, reflects a dynamic environment for tax professionals and taxpayers alike. While enhancements to the deduction cap aim to provide relief, the introduction of PTET workarounds underscores state-level innovation in tax planning. As tax landscapes shift, vigilance and proactive strategies remain paramount to optimizing tax outcomes. If your SALT deduction is impacted due to your income level, contact our office to explore potential benefits from a PTET workaround specific to your state.

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