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Maximizing SALT Deductions: Strategic Planning for Pass-Through Entities

The State and Local Tax (SALT) deduction provides taxpayers with an opportunity to deduct either their state and local income taxes or their state and local sales taxes, alongside property taxes, on their federal income tax returns when itemizing deductions. Historically, this deduction aimed to reduce the effect of double taxation on the same income.

The Era Before TCJA

Before the Tax Cuts and Jobs Act (TCJA) of 2017, taxpayers benefited from an uncapped SALT deduction, meaning they could deduct all state and local taxes paid. This was especially advantageous for residents of high-tax states like New York, California, and Illinois, who typically face higher state and local tax burdens.

With the introduction of the TCJA, however, changes were drastic. The SALT deduction became capped at $10,000 for both single and joint filers, and $5,000 for those married filing separately. This change significantly impacted taxpayers in higher-tax locales.

The Changes Under OBBBA

In recent developments, the "One Big Beautiful Bill Act" (OBBBA) has adjusted the SALT cap, lifting it starting in 2025 to a more permissible $40,000, which will see a 1% increase each year up to 2029. Absent further legislative action, the cap will revert to $10,000 afterward.

SALT DEDUCTION CAP
YearSALT 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

Many representatives from high-tax states advocated for this adjustment to offer relief to constituents. The higher cap is anticipated to benefit more taxpayers who choose to itemize, although high-income residents may face new obstacles.

High-Income Taxpayer Limitations

The OBBBA introduces phased limitations for high-income earners. These taxpayers see a reduction of their SALT deduction when their modified adjusted gross income (MAGI) surpasses specific thresholds. For example, in 2025, taxpayers with a MAGI over $500,000 face a deduction reduction at 30% of the overage, reducing the benefit of the new SALT cap for these earners. Those with MAGIs at $600,000 or greater revert to the $10,000 deduction, neutralizing the cap increase.

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Outlined below are the MAGI phase-out thresholds over time:

SALT DEDUCTION REDUCTION
YearMAGI Phase Out ThresholdMAGI - 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

Two scenarios highlight these limitations:

  • Scenario #1 (2027): A taxpayer with a $523,000 MAGI could originally claim a $40,804 SALT deduction. Given MAGI exceeds $510,050, a deduction reduction of $3,885 occurs, bringing the SALT deduction down to $36,919.
  • Scenario #2 (Maximum Reduction in 2027): A taxpayer with $615,000 MAGI would begin with the same $40,804 deduction. Yet, since their MAGI supersedes $612,730, the deduction defaults to $10,000.

Exploring Pass-Through Entity Solutions

In light of the SALT deduction cap, several states have pioneered passthrough entity tax (PTET) structures. These arrangements allow entities like S corporations and partnerships to handle state taxes at the entity level, thereby bypassing the individual SALT cap for partners and shareholders. This technique is instrumental in high-tax areas for optimizing tax efficiency amidst federal restrictions, aligning with IRS stipulations, and integrating into broader business tax planning.

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Conclusion

The evolution of SALT deductions underscores a dynamic intersection of federal actions and taxpayer adaptation strategies. The OBBBA offers temporary relief from the restrictive TCJA, yet brings challenges for high-income individuals. Meanwhile, PTET options illustrate both state innovation and taxpayer efforts in navigating complex tax laws for optimal financial outcomes. Taxpayers in Maitland and beyond must remain diligent, ensuring strategies are tuned to both current rules and potential legislative shifts.

To explore how a PTET arrangement might benefit you amid SALT deduction challenges, particularly due to your MAGI, please reach out to our office. We offer specialized insights into Florida's tax landscape, helping local businesses and individuals achieve compliance and efficiency in their tax obligations.

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