Maximizing SALT Deductions: Strategic Approaches for Passthrough Entities

The State and Local Tax (SALT) deduction has long been a cornerstone of tax mitigation strategies, allowing taxpayers to deduct state and local income or sales taxes alongside property taxes from their federal income tax returns. This has especially been beneficial for residents of high-tax states, aiming to offset the burden of double taxation.

Understanding SALT Deduction Evolution Post-TCJA

Before the 2017 Tax Cuts and Jobs Act (TCJA), taxpayers enjoyed an uncapped SALT deduction. This generous provision significantly benefited those in high-tax states such as New York, California, and Illinois. Unfortunately, the TCJA introduced a cap of $10,000 on SALT deductions for both single and married filers, drastically limiting tax relief for many.

However, recent legislative changes brought forth by the "One Big Beautiful Bill Act" (OBBBA) have adjusted this cap. Starting in 2025, the limit will increase to $40,000, with an annual 1% rise until 2029. Nonetheless, without further congressional action, this cap will revert to $10,000.

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The aim of these changes is to offer relief to taxpayers in high-tax states, enabling them to retain more from their state tax payments when itemizing deductions federally.

Considerations for High-Income Taxpayers

The OBBBA introduces specific limitations for high-income individuals. It phases out available SALT deductions based on modified adjusted gross income (MAGI). For instance, in 2025, a MAGI beyond $500,000 prompts a deduction decrease, reducing the benefits of the elevated SALT cap. Once MAGI hits $600,000, the deduction potential contracts to $10,000, negating additional benefits.

To illustrate these constraints:

  • Example #1 (2027): A taxpayer with a $523,000 MAGI could deduct up to $40,804. Exceeding the MAGI threshold results in a deduction reduction, capping it at $36,919.
  • Example #2 (Maximum Reduction in 2027): A taxpayer with $615,000 MAGI faces a capped deduction at $10,000.

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Navigating Passthrough Entity Solutions

States have innovated around these federal limits by crafting passthrough entity tax (PTET) workarounds. These allow S corporations and partnerships to pay state taxes at the entity level, sidestepping individual SALT caps. This strategic maneuver affords an entity-level deduction while state-level tax credits support individual partners or shareholders.

This approach not only aligns with IRS regulations but also delivers a critical tax efficiency tool for businesses in high-tax states, illustrating a refined method to tackle federal constraints.

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Conclusion

The dynamic landscape of SALT deductions evolves with legislative changes and innovative taxpayer strategies. While the OBBBA offers temporary reprieve for select taxpayers, passthrough entity tax solutions reflect a proactive and refined response to federal constraints. These measures highlight the importance of strategic tax planning and adaptability in optimizing liabilities under shifting regulations.

If you’re impacted by SALT deduction limitations, consult with our team at Tax Time 365 to explore how PTET strategies might benefit you. Let us guide you through maintaining compliance and optimizing your tax position effectively.

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