Strategic Tax Planning: Maximizing SALT Deductions Amid Policy Shifts

The State and Local Tax (SALT) deduction serves as a critical tool for taxpayers wishing to reduce their federal tax burden by allowing deductions for either their state and local income taxes or their state and local sales taxes, as well as property taxes, when itemizing. This mechanism has been integral in reducing double taxation on the same income, a concern particularly significant in high-tax states.

Understanding the Pre-OBBBA Landscape

Before the Tax Cuts and Jobs Act (TCJA) of 2017, the SALT deduction had no cap, which meant taxpayers could potentially subtract the entirety of their state and local taxes paid from their federal tax obligations—an advantage for residents of states like New York, California, and Illinois. However, the TCJA imposed a $10,000 cap on SALT deductions per return, significantly impacting taxpayers in these regions.

With the recent enactment of the "One Big Beautiful Bill Act" (OBBBA), this cap will undergo modification starting in 2025. The adjustment raises the deduction limit to $40,000, with incremental annual increases set to culminate at $41,624 by 2029, reverting to $10,000 thereafter, absent further legislative changes.Image 1

This shift is a legislative response to appeals from high-tax state representatives, allowing greater tax relief for taxpayers who itemize deductions on their federal returns.

Implications for High-Income Groups

High earners face specific restrictions under the OBBBA, which institutes a phase-out of the SALT deduction based on modified adjusted gross income (MAGI). For 2025, deductions begin diminishing for MAGI exceeding $500,000, with the allowance reduced by 30% for income above the threshold. Thus, individuals with $600,000 or more in MAGI see their deduction shrink back to $10,000, effectively nullifying the benefits of the increased cap. Observers can reference our accompanying tables for yearly adjustments.Image 2

Exploring Passthrough Entity Workarounds

Several states have introduced passthrough entity tax (PTET) strategies, enabling businesses structured as S corporations or partnerships to have state taxes paid at the entity level. This approach allows these businesses to claim federal deductions for state taxes at the entity level, effectively bypassing the individual cap on SALT deductions. Business owners then benefit from state-level tax credits.Image 3

These strategic PTET workarounds, compliant with IRS guidelines, are pivotal for high-income taxpayers in businesses facing substantial state tax obligations, allowing them to leverage entity-level deductions for optimal tax efficiency in high-tax states.

Conclusion: Navigating a Complex Tax Terrain

The SALT deduction landscape is evolving, impacted by legislative revisions and strategic taxpayer responses. The OBBBA has provided temporary relief beyond the TCJA's stringent limits, though higher-income individuals face phase-out based on MAGI. At Veritas Planning Advisors, we specialize in proactive tax strategies like PTET, ensuring clients maximize deductions amid federal constraints. For personalized guidance on optimizing your SALT and entity structure, contact us to explore solutions tailored to your financial landscape.

Connect with us to determine if PTET mechanisms can benefit you and to craft a tailored fiscal strategy amid these ongoing changes.

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