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Maximizing SALT Deduction Benefits Through Strategic Tax Planning

The State and Local Tax (SALT) deduction has been a crucial element in the U.S. tax code, allowing taxpayers to deduct their state and local income or sales taxes, along with property taxes, on federal income tax returns when itemizing deductions. It serves the vital function of reducing double taxation impacts on the same income parcel.

Exploring the Pre-OBBBA Landscape

Before the Tax Cuts and Jobs Act (TCJA) of 2017, taxpayers benefited from an uncapped SALT deduction, allowing full deduction of all state and local taxes paid—a particularly advantageous policy for residents in high-tax states like New York, California, and Illinois.

However, the TCJA's enactment brought substantial modification. The SALT deduction was capped at $10,000, affecting both single filers and those married filing jointly, while married individuals filing separately saw a $5,000 cap. This change significantly impacted taxpayers from high-tax states, where state and local taxes often surpassed this new federal ceiling.

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Understanding the OBBBA's Amendments

With the advent of the "One Big Beautiful Bill Act" (OBBBA), modifications to the SALT deduction cap are on the horizon. From 2025, taxpayers will see the cap rise to $40,000, with an anticipated annual increase of 1% until it reaches its zenith in 2029. Post-2029, in the absence of new legislative reprieve, the cap is slated to revert to $10,000.

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

This strategic policy adjustment aims to address the discontent from high-tax states’ congressional representatives, making it possible for more taxpayers in states with elevated tax rates to enjoy a reprieve, provided they are itemizing on their federal returns.

Limitations Impacting Wealthier Individuals

The OBBBA also introduces oversight for high-earning taxpayers through a gradual phase-out based on modified adjusted gross income (MAGI) thresholds. Starting in 2025, individuals with a MAGI above $500,000 will see a decrease in their allowable deduction by 30% of any income surpassing this benchmark. Consequently, those with a MAGI of $600,000 or higher will witness a deduction shrinkage back to the $10,000 footing.

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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

Illustrative Scenarios

Consider these scenarios:

  • Example #1 (2027): A taxpayer with $523,000 MAGI begins with a $40,804 SALT deduction (referenced previously). However, as $523,000 exceeds the $510,050 threshold, deduction phases down by $3,885, yielding a final deduction of $36,919.

  • Example #2 (Max Reduction in 2027): If a taxpayer’s MAGI hits $615,000, they start at $40,804 but surpass the $612,730 threshold crossway, reverting them to a $10,000 deduction—nullifying the increase.

The Passthrough Entity Tax Win-Win

In reaction to federal limitations, states are increasingly pursuing passthrough entity tax (PTET) strategies. These strategies empower businesses organized as partnerships or S corporations to remit state taxes at the entity level, rather than imposing them on individual partners or shareholders. This method allows the entity to take a deduction for state taxes paid on the federal return, bypassing the SALT cap imposed on individuals, and providing a state tax credit to owners.

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Such tax strategies are proving effective in states, permitting taxpayers to navigate around federal constraints while continuing to optimize tax liabilities through exhaustive entity-level deductions. It reflects a profound state-level legal maneuvering paired with a taxpayer’s strategic versatility.

Conclusion

The trajectory of SALT deductions remains complex, driven by law shifts and taxpayer innovation. While the OBBBA modifies the rigorous $10,000 limit established by the TCJA—albeit temporarily and with high-income qualifiers—state-implemented PTET solutions highlight adaptive strategies in the face of federal limitations.

Employing these stratagems not only represents an astute taxpayer response, buoyed by localized legislation but underscores the necessity for ongoing strategic tax management amid evolving legal circumstances. Taxpayers must keep abreast of these developments to maintain optimal tax efficiency. If your SALT deduction is diminishing due to MAGI, consult our office regarding a PTET solution in your jurisdiction.

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