Maximizing SALT Deductions and Passthrough Strategies

The State and Local Tax (SALT) deduction is a critical component of tax planning, allowing taxpayers to deduct their state and local income or sales taxes, plus property taxes, on federal tax returns when itemized. Historically intended to reduce double taxation, the SALT deduction is particularly important for individuals in high-tax states.

Understanding the Pre-TCJA Landscape

Before the Tax Cuts and Jobs Act (TCJA) of 2017, there was no federal cap on the amount that could be claimed through SALT deductions. This provision was invaluable for residents of states like New York, California, and Illinois, where local taxes are high.

Post-TCJA, however, the landscape changed significantly. Taxpayers now face a $10,000 cap on the SALT deduction, a restriction that impacts many in high-tax jurisdictions.

The Role of the "One Big Beautiful Bill Act" (OBBBA)

With the passing of the OBBBA, changes to the SALT cap have been introduced to provide some relief. As of 2025, the cap will increase to $40,000, climbing annually by 1% until 2029. From 2030 onward, the cap returns to $10,000 unless further legislative adjustments are made. These changes respond to demands for fairness from Congressional members of high-tax states.

The new regulations allow more taxpayers to benefit from itemizing deductions, as illustrated in the following table:

YearSALT Cap
2024$10,000
2025$40,000
2026$40,400
2027$40,804
2028$41,212
2029$41,624
2030 and onwards$10,000

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High-Income Phase-Outs

Despite these adjustments, higher-income taxpayers encounter new phase-out restrictions based on their Modified Adjusted Gross Income (MAGI). Starting in 2025, deductions are scaled down for those surpassing income thresholds, with substantial reduction for incomes exceeding $500,000.

Consider the following example to illustrate the phased impact:

  • Example 2027: A taxpayer with a MAGI of $523,000 begins with a $40,804 deduction but will see a reduction, adjusting the deduction to $36,919 due to exceeding the $510,050 threshold.
  • Maximum Reduction 2027: A MAGI of $615,000 results in a deduction reduced to $10,000 given it exceeds the $612,730 cap.

Adapting Through Passthrough Entities

Faced with these limits, many states have introduced Passthrough Entity Tax (PTET) strategies, enabling S corporations and partnerships to navigate the cap by paying state taxes at the entity level. This method allows the deduction of state taxes at the federal level while individual owners capitalize on state credits, seamlessly bypassing the SALT cap.

This mechanism serves as a practical solution to optimize tax liabilities for business owners in high-tax areas, aligning state initiatives with federal regulations in innovative tax planning.

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Concluding Insights

The evolving dynamics of SALT deductions, influenced by the OBBBA and creative state solutions, demonstrate a complex but critical area for strategic tax planning. As federal limits push taxpayers to adapt, passthrough strategies provide viable opportunities to mitigate these challenges.

It is imperative for taxpayers, especially those in high-tax areas, to review and adjust their strategies proactively. Please consult with our office to explore PTET options that may benefit your specific circumstances.

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