Maximizing Benefits with SALT Deduction Adjustments and Passthrough Entity Strategies

The State and Local Tax (SALT) deduction has long been a cornerstone of tax planning for individuals who itemize their deductions, allowing them to deduct either state and local income or sales taxes, as well as property taxes, from their federal income tax returns. This deduction is instrumental in alleviating the burden of double taxation at the state and federal levels.

Transformations Under the TCJA

The landscape of the SALT deduction significantly shifted with the Tax Cuts and Jobs Act (TCJA) of 2017. Prior to this, taxpayers could fully deduct their state and local tax payments, a privilege deeply valued by residents in states with high tax rates like New York, California, and Illinois. However, the TCJA imposed a $10,000 cap on the SALT deduction for individual and joint filers, and $5,000 for separate filers. This limitation impacted many taxpayers whose local taxes exceed these caps.

The Evolving SALT Cap under OBBBA

Responding to the pressures from high-tax states, the One Big Beautiful Bill Act (OBBBA) introduces a more accommodating SALT deduction cap set to commence in 2025. The cap will increase to $40,000, with an increment of 1% annually, peaking in 2029. Without further legislative measures, it is slated to revert to $10,000 post-2029.

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Navigating changes in the SALT deduction can provide significant relief in high-tax jurisdictions.

While this revision aims to provide relief, it notably includes a phase-out that affects high-income individuals. The deduction will lessen as a taxpayer's Modified Adjusted Gross Income (MAGI) exceeds certain thresholds, as detailed in the accompanying table.

Year SALT Cap
2024 $10,000
2025 $40,000
2026 $40,400
2029 $41,624
2030 and subsequent years $10,000

½ those amounts for married couples filing separately

Navigating High-Income Limitations

For affluent taxpayers, the OBBBA sets forth a reduction model where the deductible amount decreases when MAGI surpasses established limits. For example, in 2025, a MAGI over $500,000 reduces the deduction by 30% of the income exceeding the threshold. Hence, for incomes of $600,000 or more, the benefit of the cap enhancement may become negligible.

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Understanding and navigating phase-out thresholds can be crucial for high-income taxpayers.

The Strategic Advantage of Passthrough Entity Tax Solutions

To counteract the federal SALT cap, various states have formulated passthrough entity tax (PTET) alternatives. These taxation mechanisms target S corporations and partnerships, transferring the tax obligation to the entity level. Subsequently, businesses can claim state tax deductions federally, circumventing the SALT deduction limitations faced by individuals. This approach stands as a viable option amid stringent federal constraints, particularly in regions with significant state tax liabilities.

This innovative tactic is increasingly adopted as both states and businesses navigate federal limitations while seeking improved tax positions under evolving regulations.

Conclusion: Evolving Tax Planning Landscape

The recent amendments in SALT deductions underscore a continually shifting tax landscape shaped by legislative adaptations and proactive taxpayer strategies. The temporary relief offered by the OBBBA, alongside state-level PTET provisions, reflects a pivotal balance in tax planning where federal limitations and state ingenuity intersect. Maintaining acumen in tax strategy will be essential for those navigating these changes.

For assistance in understanding how state PTET workarounds can affect your SALT deduction, particularly if you're impacted by MAGI limitations, do not hesitate to reach out to our office.

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