Maximizing SALT Deductions: Navigating Changes and Strategic Entities

The intricate landscape of the State and Local Tax (SALT) deduction has undergone significant transformations, impacting taxpayers nationwide. Historically, the SALT deduction has allowed taxpayers to reduce taxable income by deducting state and local income or sales taxes, as well as property taxes, when itemizing on their federal returns. This tax code staple was originally crafted to alleviate the burden of double taxation.

The Landscape Before TCJA Reforms

Prior to the Tax Cuts and Jobs Act (TCJA) in 2017, taxpayers enjoyed uncapped SALT deductions, significantly benefiting those in high-tax states like New York, California, and Illinois. Image 1 However, the TCJA imposed a $10,000 cap on this deduction for both single and joint filers, or $5,000 for those married filing separately. This limitation greatly impacted residents of high-tax regions, where state and local taxes commonly breach the federal ceiling.

Adapting to the "One Big Beautiful Bill Act" (OBBBA)

The recent "One Big Beautiful Bill Act" (OBBBA) ushers in a revised SALT deduction cap, beginning in 2025, with a notable increase to $40,000 and an annual adjustment of 1% until its peak in 2029. Post-2029, barring any legislative updates, 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 and subsequent years $10,000

½ those amounts for married couples filing separately

The OBBBA addresses cap adjustments in response to advocacy from lawmakers in high-tax states, enhancing potential benefits for those itemizing deductions.

Threshold Adjustments for High-Income Filers

Under OBBBA, limitations arise for higher-income taxpayers with deductions phased out once modified adjusted gross income (MAGI) surpasses set limits. As of 2025, taxpayers exceeding $500,000 in MAGI see reductions of 30% for income beyond this threshold. Importantly, MAGI over $600,000 results in deductions capped at $10,000, regardless of other parameters. This initiative aims to foster equity by ensuring the enhanced caps support mid- to lower-income taxpayers.

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

Case Scenarios of SALT Deduction Limitations

Image 3

Consider two cases:

  • Scenario #1 (2027): A taxpayer with a MAGI of $523,000 starts with a $40,804 deduction, but since income surpasses the $510,050 threshold, it reduces by $3,885, equaling a $36,919 deduction.

  • Scenario #2 (2027 Reduction Maximum): A MAGI of $615,000 results in a deduction limited to $10,000, despite starting at $40,804, due to exceeding the $612,730 threshold.

Optimizing Tax Outcomes with Passthrough Entities

In light of federal deduction caps, states have adopted passthrough entity tax (PTET) laws to circumvent obstacles. By allowing S corporations or partnerships to fulfill state tax obligations at the entity level, business owners harness entity deductions to counter federal restrictions. This offers a dual benefit: federal deductions are maximized, and individual owners receive state tax credits.

Image 2

Adopting PTET mechanisms can greatly influence tax efficiencies, especially within high-tax areas, as taxpayers work creatively to ensure compliance while pursuing advantageous tax planning strategies.

Conclusion

The SALT deduction climate continues to evolve, underscored by legislative amendments and taxpayer adaptability. The OBBBA provides limited relief from the restrictive $10,000 cap initially enforced by the TCJA, though it remains crucial for high-income taxpayers to carefully navigate this terrain. Meanwhile, the innovation of passthrough entity tax (PTET) solutions highlights state-level ingenuity that counters federal measures, promoting an adaptive strategy for those in high-tax states.

For tailored strategies, particularly if your modified adjusted gross income influences your deduction potential, contact our office to explore passthrough entity options.

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