State Pass-Through Entity Tax Elections: The SALT Workaround

IRS Notice 2020-75  •  Entity-Level Deduction  •  Resident Credit Mechanics  •  OBBBA $40K SALT Cap
IRC §164(b)(6) Notice 2020-75 37+ States Active
← Business & Entity

The SALT cap under TCJA limited individual deductions for state and local taxes to $10,000 per year. OBBBA P.L. 119-21 raises that to $40,000 for married filing jointly (2025-2029), with phase-down above $500,000 MAGI and reversion to $10,000 after 2029. But for pass-through business owners - partners, S-corp shareholders - there is a separate workaround that predates and survives any SALT cap: the pass-through entity tax (PTET) election. Under IRS Notice 2020-75, a state-level tax paid by the entity is a fully deductible business expense on the federal return, bypassing the individual SALT cap entirely. If your state has a PTET and your partnership or S-corp has not evaluated an election, this is likely a missed deduction.

How the PTET Workaround Functions

Step 1: Partnership or S-corp elects into state PTET and pays state income tax at the entity level.

Step 2: Entity deducts the PTET as a business expense on the federal return - reducing K-1 ordinary income to partners/shareholders. Not limited by the individual §164(b)(6) SALT cap because it is the entity paying, not the individual.

Step 3: Partners/shareholders claim a credit on their state return for their share of PTET paid. The state tax is not paid twice - the individual credit offsets the entity's state payment. Net result: full federal deduction, no SALT cap, state-level wash.

Why This Works: Notice 2020-75

TCJA's §164(b)(6) capped individual deductions for state and local taxes at $10,000 (since 2018). It said nothing about entity-level state taxes. IRS Notice 2020-75 clarified that a state-imposed entity-level income tax on a partnership or S-corp is deductible at the entity level and is not an individual SALT deduction subject to §164(b)(6). The entity's deduction flows through the K-1 and reduces each owner's ordinary income without touching that owner's individual SALT cap. Over 43 states have now enacted PTET regimes to give their residents this benefit.

OBBBA Update: $40,000 Household SALT Cap

OBBBA P.L. 119-21 raised the individual SALT deduction cap from $10,000 to $40,000 for tax years beginning in 2026, phasing down to $10,000 for households with MAGI above $500,000. The PTET benefit is most pronounced for high-income pass-through owners who (a) have state tax bills far exceeding $40,000 or (b) have MAGI above $500,000 and still face the $10,000 cap. For a New York City partner earning $2M of K-1 income, state and city taxes can exceed $200,000 - the individual SALT cap covers almost none of it. The PTET election converts that $200,000+ to a fully deductible entity expense.

OBBBA changes the SALT math but does not eliminate PTET value. Model each owner separately: compare their personal SALT cap (after OBBBA phase-out) against the state tax attributable to their pass-through income. The larger the gap, the more the PTET election is worth at the federal level.

State-by-State: Major PTET Regimes

StateEntities EligibleRateElection TimingKey Notes
New YorkPartnerships, S-corps (not SMLLCs)6.85% - 10.9% on entity incomeAnnual election by March 15 following year (with extension)Mandatory for all owners once elected; resident credit equals PTET paid; NYC has separate PTET
CaliforniaPartnerships, multi-member LLCs, S-corps9.3% flat on qualified net incomeFirst installment due June 15 of the tax year; miss it, lose the electionNon-refundable credit; carries forward 5 years; requires June 15 cash outlay mid-year
New JerseyPartnerships, S-corpsGraduated 5.675% - 10.9%Annual election100% refundable credit to individual owners; particularly strong PTET benefit
IllinoisPartnerships, S-corps4.95%Annual electionNon-refundable credit; based on distributable share
ConnecticutAll pass-throughs - mandatory6.99%Mandatory - no election required or availableFirst state PTET (enacted 2018); applies automatically to all CT partnerships and S-corps
MassachusettsPartnerships, S-corps5%Annual electionCredit on individual return; covers both MA residents and non-residents with MA-source income
California's June 15 deadline is the most commonly missed. Unlike most states where you can elect at filing, California requires a first installment payment by June 15 of the tax year to preserve the election. A calendar-year partnership that does not pay by June 15, 2026 cannot make the 2026 PTET election regardless of what happens at the October 15 filing deadline. Build a calendar reminder in Q1 of each year for every California entity.

When PTET Does Not Make Sense

The election is not universally beneficial. It typically does not make sense when owners have large operating losses that eliminate federal taxable income (a deduction you cannot use is worthless); when non-resident partners in multiple states face stacking issues where the credit mechanism is incomplete; when the entity has C-corp partners who cannot use the individual credit; or when the entity is a single-member LLC treated as a disregarded entity (not eligible in most states).

Authority: IRC §164(b)(6) (SALT cap - individual deduction for state and local taxes limited; TCJA $10,000; OBBBA P.L. 119-21 raised to $40,000 for tax years beginning in 2026 with phase-out above $500,000 MAGI); IRS Notice 2020-75 (clarifies that state and local income taxes imposed on and paid by a partnership or S-corp are deductible at entity level; not subject to §164(b)(6) SALT limitation; credit or deduction must be allowed by state); IRC §164(a)(3) (state income taxes deductible as business expense at entity level); NY Tax Law §860-ET through §860-EZ (New York PTET - elective; rates 6.85%-10.9%; individual resident credit equal to share of PTET paid; enacted 2021 effective retroactively for 2021); NY Department of Taxation and Finance TSB-M-21(1)C (NY PTET guidance and credit mechanics); Cal. Rev. and Tax. Code §19900-19902 (California elective PTE tax - AB 150 enacted 2021; 9.3% flat rate; June 15 prepayment requirement for annual election; non-refundable credit; 5-year carryforward); NJ P.L. 2019, c. 320 as amended (New Jersey Business Alternative Income Tax - graduated rates; refundable credit); CT Gen. Stat. §12-699e (Connecticut mandatory PTE tax - first state PTET enacted 2018; 6.99%); IRS FAQ on PTET (IRS.gov - confirms Notice 2020-75 treatment; entity-level SALT not limited by §164(b)(6)).
tk.cpa AI Lab
Mission Privacy tk.cpa
Nothing on this page constitutes legal, tax, accounting, or professional advice, and no professional relationship is created by your use of this website. CPA Validated is an educational website for information purposes only. Information should be verified against current primary authority, including the Internal Revenue Code, Treasury regulations, IRS guidance, and applicable state or local law, before being relied upon or acted on. Calculator outputs are estimates only and may be incomplete or inaccurate depending on the facts, assumptions, and inputs used. CPA Inc. and tk.cpa disclaim liability to the fullest extent permitted by law. Full disclaimer: cpavalidated.com/disclaimer.html