Learning Center

We keep you up-to-date on the latest tax changes and news in the industry.

Maximizing SALT Deductions: Strategic Passthrough Entity Tax Solutions

The State and Local Tax (SALT) deduction has been a vital component of the tax landscape, allowing taxpayers to deduct their state and local income or sales taxes alongside property taxes on federal returns when opting for itemization. This deduction primarily addresses the burden of double taxation on the same income.

Historical Context Pre-TCJA

Before the Tax Cuts and Jobs Act (TCJA) of 2017, taxpayers were not constrained by a deduction cap, enabling full deduction of state and local taxes paid. This policy was particularly advantageous to those in high-tax states like New York, California, and Illinois.Image 1

However, TCJA introduced a $10,000 cap for combined SALT deductions for both single filers and married couples, drastically impacting those in high-tax regions.

Updates via OBBBA

The "One Big Beautiful Bill Act" (OBBBA) has since revised these provisions, raising the cap to $40,000 starting in 2025 with an incremental 1% annual increase until 2029. After 2029, without further legislation, the cap reverts to $10,000.

SALT DEDUCTION CAP

Year

SALT Cap

2024

$10,000

2025

$40,000

2026

$40,400

2027

$40,804

2028

$41,212

2029

$41,624

2030 & beyond

$10,000

½ of these amounts for separate filers

Image 2

This adjustment was instigated following advocacy from legislators in high-tax regions, enhancing benefits for those itemizing their deductions.

High-Income Taxpayer Constraints

The OBBBA also introduces deduction limitations for higher-income earners, with a phased reduction starting at specific MAGI thresholds. For example, in 2025, taxpayers with MAGI exceeding $500,000 face a 30% reduction on the excess, severely limiting the benefits of the increased SALT cap. For MAGI over $600,000, the deduction remains $10,000. This balanced approach aims to maintain equity within the tax system.Image 3

SALT DEDUCTION REDUCTION

Year

MAGI Phase Out

Reduced to $10,000

2025

$500,000

$600,000

2026

$505,000

$606,333

2027

$510,050

$612,730

2028

$515,150

$619,190

2029

$520,302

$625,719

Scenario Illustrations for High-Income Limitation

Consider these scenarios:

  • Example #1 (2027): A taxpayer with a $523,000 MAGI starts with a $40,804 deduction. Exceeding the $510,050 threshold reduces the allowable deduction to $36,919 due to a $3,885 decrease.

  • Example #2 (2027): A $615,000 MAGI results in capping the deduction at $10,000, with a MAGI beyond $612,730.

Leveraging Passthrough Entities

In response to federal SALT deduction caps, states have enacted passthrough entity tax (PTET) strategies, enabling income-tax obligations to be addressed at the entity level. PTETs permit businesses like S corporations or partnerships to shoulder state tax obligations at the entity level, thus bypassing individual caps on federal SALT deductions, and allowing individual owners to claim a state tax credit. This innovative approach has emerged as an effective tax strategy for high-income earners, particularly in states with substantial tax burdens. By capitalizing on entity-level deductions, businesses can optimize their tax positions while remaining compliant with IRS policies, reflecting a strategic fusion of state policy and taxpayer ingenuity.Image 3

Conclusion

The evolution of the SALT deduction framework marks significant legislative and taxpayer strategy shifts. The OBBBA adjusts the restrictive TCJA cap, albeit temporarily, with trade-offs for high earners. In parallel, PTET workarounds underscore state-level ingenuity, providing pathways for tax optimization. These changes necessitate proactive taxpayer engagement to navigate tax obligations efficiently amidst evolving laws. For those affected by MAGI-related SALT reduction, PTET solutions offer potential benefits according to state-specific regulations.

Your SALT deduction strategies may need reevaluation under the new tax laws. Please reach out to our office for guidance on PTET options within your state.Image 2

Share this article...

Want our best tax and accounting tips and insights delivered to your inbox?

Sign up for our newsletter.

I confirm this is a service inquiry and not an advertising message or solicitation. By clicking “Submit”, I acknowledge and agree to the creation of an account and to the and .