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Maximizing Benefits: Analyzing SALT Deduction Adjustments and Passthrough Options

The State and Local Tax (SALT) deduction permits taxpayers to deduct their state and local income, sales, and property taxes when itemizing on federal returns. This provision aims to reduce double taxation. Despite being a stable element of the tax code, recent changes under the "One Big Beautiful Bill Act" (OBBBA) have augmented this deduction's limits.

Pre-OBBBA Adjustments

Before the 2017 Tax Cuts and Jobs Act (TCJA), there was no limit to the SALT deduction, allowing significant relief to taxpayers in high-tax states like New York and California. However, TCJA introduced a cap of $10,000, significantly impacting residents in these high-tax regions.

Post-OBBBA Enhancements

With the OBBBA's enactment, the SALT deduction cap rises to $40,000 starting in 2025, incrementally increasing by 1% annually until 2029. This legislative change addresses concerns from high-tax state constituents, offering broader relief and improving the tax landscape for those itemizing deductions.

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 separate

These changes, though temporary, reflect the concerted efforts to mitigate the financial burden on taxpayers from high SALT states.

Constraints on High-Income Filers

The OBBBA introduces a phased reduction based on modified adjusted gross income (MAGI). Beginning in 2025, taxpayers with MAGI above specific thresholds will see a 30% deduction reduction for income above these limits, affecting their potential savings from the SALT cap. This mechanism serves to balance the tax landscape by moderately curtailing benefits for wealthier taxpayers, maintaining equity.

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

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Illustrative Cases of Constraints

Here are some practical scenarios:

  • Scenario #1 (2027): A taxpayer with a MAGI of $523,000 initially has a SALT deduction of $40,804, which decreases due to the income level, resulting in a reduced deduction of $36,919.

  • Scenario #2 (Max Reduction in 2027): With a MAGI of $615,000, the taxpayer's SALT deduction is sharply adjusted to $10,000.

Exploring Passthrough Entity Strategies

States have creatively countered the federal SALT cap by enacting passthrough entity tax (PTET) solutions. These PTET arrangements allow entities like S corporations and partnerships to pay state taxes at the entity level. This method provides entity-level deductions against state taxes, which are lucrative because they sidestep federal SALT caps. Taxpayers can then use state tax credits, significantly benefiting business owners and investors burdened by substantial state taxes, especially in high-tax jurisdictions.

Final Thoughts

The dynamics of SALT deductions continue to evolve, requiring diligent attention from taxpayers and consultants alike. The enhanced limits under the OBBBA offer temporary relief, while the introduction of PTET provides strategic planning opportunities to navigate these federal limits effectively. As rules shift, and taxpayers seek to optimize their liabilities, staying informed and engaging with knowledgeable advisors are crucial steps in managing one's tax strategy efficiently. For assistance tailored to your situation, reach out to Michael Dolezal & Co, your expert advisors at (216) 485-2028 or info@cpaneeds.com.

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