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Maximizing Benefits from SALT Changes for Business Entities

The State and Local Tax (SALT) deduction has long played a vital role in protecting taxpayers from double taxation on the same income. By allowing deductions for either state and local income taxes or sales taxes in addition to property taxes, this provision has been integral to federal tax returns, especially for residents in high-tax states when they itemize deductions.

Pre-TCJA Era: Uncapped Benefits

Before the Tax Cuts and Jobs Act (TCJA) of 2017, there was no ceiling on the SALT deduction. Taxpayers could deduct all their paid state and local taxes when itemizing federal returns, a generous provision particularly advantageous for states like New York, California, and Illinois. However, the TCJA significantly altered this landscape by imposing a $10,000 cap on the SALT deduction for both single and married joint filers, and $5,000 for married individuals filing separately, thereby disadvantaging many in high-tax areas. This policy shift sparked discussions and debates across the nation.

The OBBBA Modification

In response to mounting pressures, the "One Big Beautiful Bill Act" (OBBBA) introduced amendments to the SALT deduction cap, increasing it to $40,000 starting in 2025, with an annual 1% increment until 2029. Yet, without further Congressional changes, the cap is poised to revert to $10,000 by 2030.

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SALT DEDUCTION CAP SCHEDULE

Year

SALT Cap

2024

$10,000

2025

$40,000

2026

$40,400

2027

$40,804

2028

$41,212

2029

$41,624

2030+

$10,000

½ those amounts for married couples filing separately

This legislative shift was driven by representatives from high-tax states seeking relief for constituents typically burdened heavily by these taxes. The increased cap allows taxpayers who itemize to obtain greater federal tax benefits.

Challenges for Higher-Income Taxpayers

Despite the softer cap, the OBBBA imposes a phase-out mechanism based on Modified Adjusted Gross Income (MAGI) for wealthier taxpayers. For instance, in 2025, those with a MAGI over $500,000 will see their deduction start to diminish by 30% of the income over the threshold. Those with a MAGI of $600,000 or more will have their SALT deduction curtailed to $10,000.

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This built-in limitation purports to balance fairness within the taxation system across varying income brackets while providing some relief under the new cap structure. The MAGI thresholds are subject to annual adjustments as shown below:

SALT REDUCTION PARAMETERS

Year

MAGI Threshold

Full Reduction Begins at

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

Real-Life Examples

  • 2027 Scenario: A taxpayer with a $523,000 MAGI, entitled to a $40,804 SALT deduction, sees a reduction to $36,919 due to their MAGI surpassing the $510,050 threshold.

  • Maximum Reduction (2027): An individual with a $615,000 MAGI faces deduction constraints to $10,000 as their income eclipses $612,730, showing the impact of stringent phase-out rules.

Strategic Passthrough Entity Solutions

For business owners, the SALT deduction limits have prompted innovative responses from several states through the introduction of passthrough entity tax (PTET) measures. These allow S corporations and partnerships to deduct state taxes at the entity level, thus circumventing the cap on individual returns. This strategic maneuver remains compliant with IRS regulations while offering a practical solution to enhance tax efficiency.

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Conclusion

The evolution of SALT deduction rules under the OBBBA introduces a nuanced but temporary easing of federal limits, particularly benefiting those in high-tax regions. Concurrently, the strategic application of passthrough entity taxation reflects adaptive strategies by states to counteract federal constraints, positioning businesses to capitalize on entity-level tax efficiencies. As legislative landscapes continue to shift, NR CPAs & Business Advisors in Coral Gables, Florida, remains poised to guide clients through these complexities with tailored strategies that optimize their tax outcomes.

Contact us today to explore how these critical tax laws might impact your deductions and to see if PTET strategies align with your tax planning needs.

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