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Maximizing SALT Deductions with Advanced Passthrough Strategies

The State and Local Tax (SALT) deduction has traditionally enabled taxpayers to reduce their federal taxable income by deducting state and local income, sales, and property taxes. This provision is crucial, especially for those in high-tax regions, as it mitigates the burden of dual taxation on similar income streams.

Pre-TCJA Landscape

Before the Tax Cuts and Jobs Act (TCJA) of 2017, there was no upper limit on the SALT deduction, allowing taxpayers to deduct all state and local taxes paid when itemizing. This was particularly beneficial for residents in states like New York and California, where taxes are notably high. Image 1

However, the TCJA introduced a $10,000 cap on the SALT deduction, substantially impacting taxpayers in these high-tax areas, since their state and local tax liabilities often exceed this threshold.

OBBBA's Adjustments

Recently, the passage of the "One Big Beautiful Bill Act" (OBBBA) provided alterations to this framework. Starting in 2025, the cap on the SALT deduction rises to $40,000, with annual increments of 1% until 2029. Post-2029, unless further legislative interventions occur, the cap will revert 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 and subsequent years

$10,000

½ those amounts for married couples filing separately

This adjustment is a response to appeals from representatives of high-tax states, aiming to extend relief to more itemizing taxpayers. Image 2

Constraints on High-Income Earners

The OBBBA also places new limits on high-income earners by phasing out SALT deductions at higher modified adjusted gross income (MAGI) levels. For 2025, deductions decrease by 30% of income exceeding the $500,000 threshold, reverting to $10,000 for those earning $600,000 or more. This balances broad relief with equitable distribution among wealthier taxpayers. The MAGI thresholds will adjust yearly as indicated below.

SALT DEDUCTION REDUCTION

Year

MAGI Phase Out Threshold

MAGI - 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

Examples Highlighting the Impact

Consider the following scenarios:

  • Scenario #1 (2027): If a taxpayer's MAGI is $523,000, their SALT deduction initially totals $40,804. Exceeding the $510,050 threshold, they would see a decrease, landing at $36,919 due to a $3,885 reduction.

  • Scenario #2 (Maximum Reduction in 2027): A taxpayer with a $615,000 MAGI begins with a $40,804 deduction. Crossing $612,730 restricts their deduction to $10,000.

Passthrough Entity Solutions

States have devised passthrough entity tax (PTET) systems to address the federal SALT cap. These laws allow partnerships and S corporations to pay state taxes at the entity level, thereby enabling the deduction of these taxes on federal returns. This approach evades the federal cap for individual owners, simultaneously offering a state tax credit.

This method has gained traction, particularly among high-income stakeholders in high-tax areas, as it complies with IRS guidelines while optimizing tax efficiency through entity-level deductions. Hence, it serves as an integral tax planning opportunity, particularly where state taxes are considerable.

Conclusion

The evolution of SALT deductions reflects not only legislative shifts but also strategic taxpayer responses. Whether it's the elevated caps under the OBBBA or innovative state-level PTET strategies, these changes underscore the importance of ongoing tax planning and adaptation. For taxpayers, especially those with considerable state tax burdens, leveraging these mechanisms can lead to significant tax savings.

If your SALT deduction is being limited by your MAGI, contact our office to explore if your state’s PTET workaround can provide you with substantial tax relief. Image 3

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