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Maximizing Tax Benefits: SALT Deduction Revisions and Strategic Passthrough Entity Solutions

The State and Local Tax (SALT) deduction remains a crucial element in tax planning, allowing taxpayers to deduct their state and local income or sales taxes, along with property taxes, on federal income tax returns when itemizing. Traditionally, this deduction has been instrumental in preventing the double taxation of income.

Before the Enactment of TCJA

Before the Tax Cuts and Jobs Act (TCJA) of 2017, taxpayers could deduct all state and local taxes paid without limit. This was particularly advantageous for residents of high-tax states like New York, California, and Illinois.

However, the introduction of the TCJA imposed a $10,000 cap on the SALT deduction for joint filers and $5,000 for married individuals filing separately, significantly impacting high-tax state residents, where state and local taxes typically surpass the federal cap.

Implications of the One Big Beautiful Bill Act

The recent enactment of the "One Big Beautiful Bill Act" (OBBBA) amends the SALT cap, increasing it to $40,000 starting in 2025, with an annual increase until it hits a peak in 2029. Without Congressional extension, it reverts to $10,000 post-2029.

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This revision, driven by high-tax states’ congressional advocacy, purports to benefit more taxpayers who itemize on federal returns, though it includes limitations for higher-income individuals.

SALT Deduction and High-Income Taxpayers

New OBBBA provisions set a MAGI-based phase-out for higher earners. When MAGI surpasses set thresholds, the deduction is reduced. For example, in 2025, those with a MAGI above $500,000 will see a deduction reduction. Taxpayers over $600,000 will find the cap of $10,000 still applicable. The goal is to balance tax relief with equitable treatment within the tax system, with progressive MAGI thresholds applied annually.

Illustrating the Deduction Constraints

  • 2027 Scenario #1: A taxpayer with $523,000 MAGI starts with a $40,804 deduction. Exceeding the $510,050 MAGI threshold reduces it to $36,919.

  • 2027 Maximum Case: A taxpayer at $615,000 MAGI sees their deduction limited to $10,000, reflecting the minimal benefit of the increased cap.

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Utilizing Passthrough Entity Tax Solutions

The federal SALT cap prompted states to create passthrough entity tax (PTET) mechanisms, allowing entities like S corporations to pay state taxes at the corporate level, bypassing individual caps and offering a state credit to individual taxpayers. This strategy enhances tax efficiency, aligning state initiatives with existing IRS guidelines while offering a valuable planning tool in high-tax areas.

Final Thoughts

The evolution of SALT deductions, effected by legislative and strategic responses, signifies ongoing adaptation in tax strategy. The OBBBA's revised caps offer temporary relief, though high-income taxpayers might find limited benefits. Passthrough entity workarounds provide an innovative path to optimize tax liabilities despite federal limitations. Taxpayers should remain proactive, examining both interim solutions and prospective legislative shifts to maintain optimal tax efficiency.

For assistance with your specific tax situation, such as evaluating state PTET applicability, please reach out to discuss potential strategies.

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