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SALT Deduction Evolutions: Maximizing Pass-through Entity Benefits

The esteemed State and Local Tax (SALT) deduction has been a cornerstone of the U.S. tax system, empowering taxpayers to mitigate the effects of state and local income or sales taxes, alongside property taxes, through federal deductions. This strategic tax provision effectively addresses the issue of double taxation.

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Historical Context: The Pre-TCJA Landscape

Before the transformative Tax Cuts and Jobs Act (TCJA) of 2017, there existed unbounded potential in SALT deductions. Taxpayers inclined to itemize could fully leverage state and local tax payments, a boon to inhabitants of high-tax states such as New York and California.

Nonetheless, the introduction of the TCJA heralded a new era with its imposition of a $10,000 cap on SALT deductions. This restriction significantly impacted taxpayers within states notorious for their hefty tax burdens, emphasizing the necessity of strategic tax planning.

Advancements Under the OBBBA

The recent legislative milestone, the "One Big Beautiful Bill Act" (OBBBA), has ushered in advantageous amendments, slated to take effect in 2025. The SALT deduction cap will rise to $40,000, with subsequent annual increments enhancing its value until peaking in 2029. Barring Congressional intervention, the cap reverts to $10,000 post-2029.

In response to advocacy from high-tax state legislators, these provisions provide reprieve to itemizing taxpayers dwelling in such jurisdictions.

High-Income Taxpayer Limitations

The OBBBA also introduces phased deduction limitations for individuals surpassing certain Modified Adjusted Gross Income (MAGI) thresholds. Starting in 2025, those earning over $500,000 in MAGI will face a phased reduction in deductibility.

For instance, in 2025, taxpayers exceeding the MAGI threshold of $500,000 will see a decrement in their allowable deduction, capping benefits at $10,000 for income over $600,000. Variability in MAGI thresholds renders proactive financial strategic planning essential to harness the full advantage of the evolving SALT landscape.

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Strategic Passthrough Entity Opportunities

In view of the federal limitations, states have pioneered passthrough entity tax (PTET) frameworks aimed at optimizing tax efficiency for S corporations and partnerships. These mechanisms sanction state-level taxation at the entity level, thus circumventing the individual SALT cap.

Owners subsequently benefit from a state tax credit, positioning PTETs as a pivotal tax strategy for high-income business owners navigating substantial state tax liabilities. This approach ensures compliance with IRS mandates while inviting strategic tax planning in jurisdictions with significant tax rates.

Conclusion

SALT deduction dynamics continue to evolve, fueled by legislative reforms and strategic taxpayer initiatives. Despite temporary relief provided by the OBBBA, high-income individuals must remain vigilant given phased deduction restrictions. Meanwhile, PTET structures represent state ingenuity, enabling taxpayers to decrease liability while adhering to federal guidelines.

For tailored guidance on maximizing your SALT deductions or exploring PTET options, contact our office today.

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