IRC 164 SALT Deduction Cap: OBBBA Increase to $40,000 and PTET Bypass Practitioner Guide

The state and local tax (SALT) deduction under IRC 164 has been one of the most contested provisions in federal tax law since the Tax Cuts and Jobs Act capped it at $10,000 in 2017. OBBBA amended IRC 164(b)(6) to raise that cap to $40,000 (per IRC 164(b)(6) as amended by OBBBA; verify at IRS.gov) for tax year 2025, with modest annual inflation adjustments through 2029 and a legislated reversion to $10,000 on January 1, 2030 under current law. For pass-through entity owners, the most significant related planning tool is not the cap itself but the state-level pass-through entity tax (PTET) election, which routes state income tax through the entity under IRC 162 and bypasses IRC 164(b)(6) entirely.

This guide is written for enrolled agents, CPAs, and tax attorneys advising high-income individuals and pass-through entity owners. It covers the pre-OBBBA TCJA cap, the OBBBA increase, the phase-down mechanics for high earners, what counts toward the cap, the PTET bypass strategy, the Schedule A itemized deduction context, the individual AMT interaction, state credit mechanics for PTET owners, practical planning considerations, the 2030 sunset, and key FAQs. All statutory citations, regulatory references, and IRS guidance must be verified against the enacted OBBBA text, current IRC 164 and related authorities, and current IRS.gov guidance before reliance in any specific client matter. This guide is for informational purposes only and does not constitute legal or tax advice.

Section 1: Background -- The Pre-OBBBA TCJA SALT Cap

Before the Tax Cuts and Jobs Act of 2017, individual taxpayers who itemized on Schedule A could generally deduct all state and local taxes paid during the year, including state income taxes (or general sales taxes at the taxpayer's election), real property taxes, and personal property taxes. For taxpayers in high-tax states, this deduction often ran to tens of thousands of dollars and materially reduced federal taxable income.

TCJA Enacts IRC 164(b)(6): The $10,000 Cap

The Tax Cuts and Jobs Act of 2017 enacted IRC 164(b)(6), which limited the aggregate SALT deduction to $10,000 per return ($5,000 for married filing separately) for tax years beginning after December 31, 2017. This limit was written into the statute as a temporary provision, set to expire on December 31, 2025, in line with most other TCJA individual provisions. The $10,000 cap applied without regard to the taxpayer's actual state and local tax burden; a taxpayer paying $80,000 in property and income taxes to high-tax states could deduct only $10,000 under IRC 164(b)(6).

The TCJA SALT cap generated significant revenue (by denying deductions previously taken by high-income, high-tax-state taxpayers) and also generated sustained political pressure to raise or repeal it. Several states responded by enacting workarounds, most notably pass-through entity tax (PTET) regimes designed to convert individual SALT deductions into entity-level business deductions. The IRS validated the PTET approach in November 2020 via Notice 2020-75.

Congress Extended the Cap; OBBBA Then Raised It

The original TCJA SALT cap had a scheduled 2025 sunset. Congress acted to extend and then modify the cap; OBBBA amended IRC 164(b)(6) to raise the cap significantly for 2025 through 2029, with a new scheduled reversion to $10,000 on January 1, 2030. The legislative history of the SALT cap illustrates that Congress has been willing to modify the cap and may do so again before the 2030 reversion date, but practitioners must advise clients on the basis of current enacted law until Congress acts otherwise.

Section 2: The OBBBA SALT Cap Increase -- Amounts by Year

OBBBA amended IRC 164(b)(6) to raise the SALT deduction cap for tax years 2025 through 2029, subject to annual inflation adjustment. The 2030 reversion to the pre-OBBBA $10,000 level is built into current enacted law. All amounts below are sourced to IRC 164(b)(6) as amended by OBBBA; verify each year's current amount at IRS.gov before client reliance.

Verification Is Mandatory for Every Year

The inflation-adjusted SALT cap amounts for TY2026 and later are approximate until Treasury publishes the official annual adjustment. The $40,400 figure for TY2026 is the expected amount based on the statutory 1% adjustment mechanism, but the official amount must be confirmed at IRS.gov before use in any client computation. Do not use approximate figures from this guide in lieu of confirmed IRS guidance for a specific tax year.

Congress May Act Before 2030

The 2030 reversion is current enacted law as of this guide. However, the SALT cap has been the subject of repeated legislative attention. Congress extended the TCJA SALT cap before the original 2025 sunset and may modify, extend, or repeal the OBBBA cap before the 2030 reversion date. Practitioners advising clients on decisions that depend on the post-2029 SALT environment (such as PTET planning, estimated tax timing, and income acceleration/deferral decisions around 2029-2030) should build both the current-law reversion scenario and a potential-extension scenario into their multi-year models.

Section 3: Phase-Down for High Earners

OBBBA did not give every taxpayer the full $40,000 SALT cap. For taxpayers with modified adjusted gross income (MAGI) above the applicable threshold, the cap is reduced by 30 cents for each dollar of MAGI that exceeds the threshold. This "phase-down" means that sufficiently high-income taxpayers eventually see their effective SALT cap fall back to $10,000 (the floor) despite the OBBBA increase. The statutory 30% reduction rate is in IRC 164(b)(6) as amended by OBBBA.

How the Phase-Down Works

The mechanics operate as follows. Starting from the year's applicable cap (e.g., $40,000 for TY2025), the cap is reduced by 30% of the amount by which the taxpayer's MAGI exceeds the applicable threshold. The reduction cannot bring the cap below $10,000. That $10,000 floor ensures that even the highest-income taxpayers retain at least the pre-OBBBA TCJA cap amount.

By way of illustration only (not a specific client computation): a taxpayer with MAGI $100,000 above the threshold would see the cap reduced by $30,000 (30% of $100,000), bringing a $40,000 cap down to $10,000 and triggering the floor. At that point, the taxpayer retains a $10,000 SALT deduction rather than $40,000. Specific MAGI thresholds must be confirmed at IRS.gov and in applicable Treasury guidance; the thresholds may themselves be inflation-adjusted, and no specific dollar threshold is stated in this guide without that hedge.

MAGI Thresholds: Verify at IRS.gov

Specific MAGI thresholds for the OBBBA SALT phase-down must be verified at IRS.gov and in applicable Treasury guidance before any client application. Thresholds may differ by filing status (single, MFJ, MFS, head of household) and may be inflation-adjusted for years after TY2025. Practitioners should not rely on any third-party summary of the thresholds, including this guide, as the controlling source; the enacted IRC 164(b)(6) as amended and current IRS.gov guidance are the authoritative references.

Planning for Phase-Down Clients: The PTET Becomes Even More Valuable

For pass-through entity owners whose MAGI is above the phase-down threshold, the effective SALT deduction on Schedule A may be reduced to a figure well below $40,000 (or even to the $10,000 floor). In that context, the PTET bypass (discussed in Section 5 below) becomes proportionally more valuable: state income taxes paid through a PTET election are deducted at the entity level under IRC 162 and bypass IRC 164(b)(6) entirely, regardless of where the individual owner's MAGI falls relative to the phase-down threshold. A high-income owner who receives only a $10,000 SALT deduction on their own Schedule A can still benefit from the full entity-level PTET deduction passing through their K-1.

Section 4: What Counts Toward the SALT Cap

IRC 164(b)(6) limits the aggregate deduction for taxes described in IRC 164(a)(1) through (3). Practitioners must identify all state and local taxes a client paid during the year and aggregate them against the applicable cap. The following categories count:

State and Local Income Taxes (or General Sales Taxes)

State and local income taxes paid or accrued during the tax year count toward the IRC 164(b)(6) cap. In states without an income tax, a taxpayer may elect under IRC 164(b)(5) to deduct general sales taxes instead of income taxes. The election is one or the other; both income taxes and sales taxes cannot be deducted in the same year. Whichever amount the taxpayer deducts is subject to the SALT cap. The election must be made on the return for the year in question.

Real Property Taxes

State and local real property taxes paid on property owned by the taxpayer for personal use (including the taxpayer's principal residence and second home) count toward the SALT cap under IRC 164(a)(1). Real property taxes paid on business or investment property are generally deductible under a different provision (as a business or investment expense, not on Schedule A) and are not subject to the IRC 164(b)(6) cap. Practitioners should correctly classify property taxes between personal-use property (subject to the cap on Schedule A) and business/investment property (not subject to the cap).

Personal Property Taxes

State and local personal property taxes (such as annual vehicle registration fees that qualify as ad valorem personal property taxes) paid during the year count toward the SALT cap under IRC 164(a)(1). Not all vehicle registration fees qualify; only the portion that is an ad valorem tax based on the value of the personal property is deductible. Hedge the qualification criteria for personal property taxes to IRC 164(b)(1) and current IRS.gov guidance.

Foreign Real Property Taxes

Foreign real property taxes may be deductible under IRC 164 in certain circumstances where the taxpayer elects to treat them as deductible rather than as a credit. If so treated, they count toward the SALT cap alongside domestic state and local taxes. The deductibility of foreign real property taxes is a separate and fact-specific analysis; hedge any foreign real property tax treatment to IRC 164(a) and current IRS.gov guidance. This is a relatively uncommon fact pattern, but practitioners with clients owning foreign real property should confirm the applicable treatment before assuming these taxes are or are not subject to the cap.

What Does NOT Count Toward the Cap

The following do not count toward the IRC 164(b)(6) SALT cap, because they are either not deductible on Schedule A or are deductible under a different provision:

• State and local taxes paid at the entity level through a PTET election (deducted by the entity under IRC 162; not a Schedule A item for the individual owner).
• Property taxes on business property (deducted as a business expense on Schedule C, Schedule E, or Form 4835, not on Schedule A).
• Federal income taxes (not deductible under IRC 164).
• Estate taxes and gift taxes (not subject to the SALT cap even if otherwise deductible).
• Foreign income taxes for which the taxpayer claims the foreign tax credit under IRC 901 (choosing the credit makes the foreign income tax non-deductible; the credit and the deduction are mutually exclusive).

Section 5: The PTET Bypass -- The Most Important Planning Strategy for Business Owners

For individuals who own interests in partnerships or S corporations, the pass-through entity tax (PTET) election available in many states is the most significant SALT planning strategy available under current law. When properly structured and elected, a PTET converts what would otherwise be an individual Schedule A deduction (subject to IRC 164(b)(6)) into an entity-level business deduction (under IRC 162) that bypasses the SALT cap entirely.

How the PTET Bypass Works

Under a state PTET regime, a partnership or S corporation elects to have the entity itself pay state income tax on the income that flows through to its partners or shareholders. The entity pays the state tax at the entity level. The entity then deducts that state tax payment as an ordinary and necessary business expense under IRC 162(a). The deduction reduces the entity's taxable income, which in turn reduces the income reported to each partner or shareholder on Schedule K-1. Because the deduction flows through to the owners as a reduction in K-1 income (rather than as a state tax paid by the individual), the individual never claims a SALT deduction on Schedule A for that amount. IRC 164(b)(6) applies only to state and local taxes deducted by an individual on Schedule A; it does not apply to a valid entity-level business deduction under IRC 162.

The IRS confirmed this treatment in IRS Notice 2020-75 (November 2020), which states that the IRS intends to issue regulations providing that a state and local income tax imposed on and paid by a partnership or S corporation is allowed as a deduction by the partnership or S corporation in computing its non-separately stated taxable income for the year of the payment. That deduction is not subject to the SALT deduction limitation of IRC 164(b)(6) because the entity, not the individual, is the taxpayer claiming the deduction. Cite IRC 162 for the entity-level deduction authority and IRS Notice 2020-75 for the IRS position validating PTET deductibility. Verify any subsequent regulatory guidance or IRS updates at IRS.gov.

The Planning Value Is Greatest for Phase-Down Clients

For a pass-through entity owner whose individual MAGI is above the phase-down threshold, the personal Schedule A SALT deduction may be reduced to $10,000 or near the floor. The PTET election offers a path to deduct state income taxes attributable to pass-through income without any cap, because the entity-level deduction under IRC 162 is not subject to IRC 164(b)(6). A high-income partner who would receive only a $10,000 personal SALT deduction could, if the applicable state PTET is elected by the partnership, benefit from the full entity-level deduction of state income taxes paid on their share of partnership income, with no dollar cap.

Even for clients below the phase-down threshold, the PTET election is valuable if their aggregate personal SALT (income taxes plus property taxes) would exceed the $40,000 cap. By running state income taxes attributable to business income through the entity, those taxes are deducted at the entity level and do not count against the individual's $40,000 cap, preserving more of the cap for personal-use real property taxes and other SALT items.

State-by-State PTET Variation: Hedge All Mechanics to the Applicable State Statute

Every state with a PTET regime has its own law governing eligibility, election mechanics, tax rates, and the treatment of the credit flowing back to owners. No two states' PTET rules are identical, and state PTET laws have been actively legislated and modified since 2018. Practitioners must analyze each state's PTET regime separately under the applicable state statute and verify the current rules at IRS.gov and the applicable state tax authority's official guidance. No specific state PTET rate or threshold is stated in this guide; all such figures must be verified to the applicable state statute and IRS.gov before client reliance.

Election Deadlines Differ from Federal Deadlines

State PTET elections are typically made by a state-specific deadline that may differ substantially from the federal filing deadline or the partnership or S-corp extension deadline. Some states require the election to be made by a date early in the taxable year (or even before the taxable year begins); others allow the election to be made with the state return. Missing the state PTET election deadline can forfeit the benefit for the entire taxable year. Practitioners handling multi-state partnership or S-corp clients must track the PTET election deadline for every state in which the entity operates and files, not just the primary state of organization. Verify all election deadlines under the applicable state statute for each tax year.

PTET Is Not a Complete Substitute for Schedule A SALT Analysis

The PTET bypass addresses only the state income taxes attributable to pass-through entity income. It does not address the individual's personal real property taxes, personal income taxes from W-2 wages, personal property taxes, or any other SALT items that the individual pays directly. Those items still aggregate on Schedule A and are still subject to the IRC 164(b)(6) cap. PTET planning should be analyzed alongside, not instead of, a full Schedule A SALT computation for the individual.

Section 6: Itemized Deduction Context -- Schedule A and the Standard Deduction

The IRC 164 SALT deduction, including the OBBBA-increased cap, is only relevant to taxpayers who itemize their deductions on Schedule A. A taxpayer who takes the standard deduction receives no benefit from the SALT deduction regardless of how much state and local tax they paid or what the current cap is. The threshold question for every client is therefore whether itemizing produces a larger deduction than the standard deduction.

OBBBA Also Increased the Standard Deduction

OBBBA also amended IRC 63(c) to increase the standard deduction for most filing statuses. Verify the current standard deduction amounts at IRS.gov and in IRC 63(c) as amended by OBBBA; do not use the pre-OBBBA amounts. A higher standard deduction means that some taxpayers who previously itemized may no longer benefit from doing so, even with the SALT cap raised to $40,000. The decision to itemize depends on the taxpayer's total Schedule A deductions: SALT (capped), mortgage interest (subject to IRC 163(h)), charitable contributions (IRC 170), and other allowable itemized deductions. Run the comparison for each client; do not assume that a client who itemized before OBBBA continues to benefit from itemizing after OBBBA.

Who Is More Likely to Benefit from Itemizing After OBBBA

The increase from $10,000 to $40,000 (verify at IRS.gov) in the SALT cap opens the door to itemizing for more taxpayers in high-tax states who were previously constrained by the $10,000 limit. A taxpayer paying $30,000 in state income taxes and $15,000 in property taxes previously had $45,000 in SALT but could only deduct $10,000. Under the OBBBA cap, the same taxpayer could potentially deduct $40,000 in SALT (assuming no phase-down), making itemizing significantly more valuable and more likely to exceed the standard deduction. Practitioners in high-tax states should proactively model the itemized-vs.-standard comparison for clients who previously defaulted to the standard deduction because of the $10,000 SALT cap.

Section 7: AMT Interaction

For individual taxpayers with potential AMT exposure, the SALT deduction is a critical item to analyze separately for regular tax and AMT purposes.

Individual AMT (Form 6251): SALT Has Been a Preference Item

For individual AMT under IRC 55 and Form 6251, the SALT deduction has historically been a preference item: the deduction allowed for regular tax on Schedule A is disallowed for AMT purposes, adding back the SALT deduction when computing alternative minimum taxable income (AMTI). This means a taxpayer who benefits from the higher $40,000 SALT cap for regular tax purposes may find that the benefit is partially or fully erased by individual AMT if the SALT deduction drives a significant AMT adjustment.

OBBBA made changes to the individual AMT, including adjustments to the AMT exemption amounts and phase-out thresholds. Hedge all specific individual AMT interaction details to IRC 55 through 59 and current IRS.gov guidance, as the interaction of the OBBBA SALT cap increase with the revised individual AMT requires year-specific analysis. No specific AMT exemption amount or phase-out threshold is stated in this guide; verify all current figures at IRS.gov. Practitioners should compute the individual AMT separately for every client with potential exposure rather than assuming the AMT analysis is unchanged by OBBBA.

CAMT Does Not Involve the SALT Deduction

The corporate alternative minimum tax (CAMT) under IRC 55(b)(2) applies to applicable corporations and is based on adjusted financial statement income (AFSI), not on taxable income or Schedule A deductions. CAMT is entirely separate from the individual SALT analysis and the IRC 164(b)(6) cap. Practitioners handling both individual and corporate clients should not conflate the CAMT analysis with the individual SALT/AMT analysis; they are distinct regimes.

Section 8: State Income Tax Credits on PTET Payments

Most states that have enacted a PTET regime also provide a corresponding individual income tax credit to the pass-through entity owners. The purpose of the credit is to prevent economic double taxation: the entity pays state income tax at the entity level on income that also flows through to the individual owner as taxable income for state purposes. Without a corresponding credit, the owner would effectively pay state tax twice on the same income (once through the entity's PTET and again at the individual level on the K-1 income).

How the Credit Flows Through

The state credit is typically reported to each partner or shareholder on the state equivalent of Schedule K-1, and the individual claims the credit on their state income tax return. The credit reduces the individual's state income tax liability for the year. Because the credit reduces state income taxes owed at the individual level, it also may reduce the amount of state income taxes the individual actually pays personally, which in turn can reduce the SALT deduction the individual claims on Schedule A for personal state income taxes paid. Practitioners should confirm the credit mechanics under the applicable state statute and trace the impact through both the entity-level PTET deduction and the individual's state Schedule A SALT computation.

Credit Mechanics Vary Significantly by State

The percentage, refundability, carryforward rules, and other mechanics of the state PTET credit vary significantly by state. Some states provide a full dollar-for-dollar credit against the individual's state income tax for the individual's proportionate share of the PTET paid by the entity. Others provide a partial credit, cap the credit, or have other limitations. Hedge all credit mechanics to the applicable state statute and current IRS.gov guidance. Do not generalize from one state's PTET credit to another; each state's regime must be analyzed separately.

Section 9: Planning Considerations

The following planning considerations apply broadly to practitioners advising high-income individuals and pass-through entity owners affected by the OBBBA SALT cap changes. All specific recommendations must be tailored to the client's particular facts, the applicable state law, and current IRS.gov guidance; nothing in this section constitutes legal or tax advice for any specific client.

High-Income Clients in the Phase-Down Range: Model PTET vs. Reduced SALT Cap

For clients whose MAGI places them in the phase-down range, the effective SALT cap is somewhere between $10,000 and $40,000 (verify exact threshold at IRS.gov). The PTET election, where available, captures the state income tax on business income above the entity at the IRC 162 level, preserving the individual's reduced-but-positive SALT cap for real property taxes and other personal SALT items. Practitioners should model both scenarios (with and without PTET) to quantify the combined federal tax benefit for the client's specific income level and state tax profile.

State Estimated Tax Timing

For clients who itemize and have Schedule A SALT capacity remaining below the cap, the timing of state estimated tax payments can affect the year in which the deduction is claimed. A state income tax payment made in December (fourth-quarter estimated tax) is deductible in the year paid if the taxpayer is a cash-basis taxpayer, while the same payment made in January is deductible in the following year. With the cap raised to $40,000, more clients may have room to benefit from the December acceleration strategy. Conversely, if a client is at or above the cap, accelerating a state payment into December provides no additional federal deduction. The analysis depends on the client's specific SALT position and estimated tax payment schedule. Hedge all timing recommendations to client-specific facts and the applicable state's estimated tax rules.

Multi-State Income: Coordinate Primary and Secondary States

Many high-income individuals earn income in multiple states (through pass-through entities, investment properties, or work performed in multiple states). All state and local income taxes paid to any taxing jurisdiction aggregate toward the single federal SALT cap. A client paying income taxes to New York, California, and New Jersey simultaneously faces a combined SALT burden that must be analyzed in total against the applicable cap. The PTET bypass, where applicable, can help remove the pass-through entity income components from this aggregation. Practitioners handling multi-state clients should build a complete SALT picture across all jurisdictions before determining the client's cap exposure and the value of the PTET election.

Multi-Year Planning Around the 2030 Sunset

Clients making significant decisions that depend on the ongoing availability of the $40,000 SALT cap (such as purchasing a high-value personal residence in a high-tax state, relocating to reduce state income taxes, or structuring pass-through entity income) should understand that the current-law cap reverts to $10,000 on January 1, 2030. A decision that is tax-efficient under the current $40,000 cap may be materially less efficient under a $10,000 cap. Build the 2030 reversion scenario into any multi-year projection. At the same time, as noted throughout this guide, Congress has legislated on the SALT cap before and may act again; update client projections if and when Congress acts.

Section 10: The 2030 Sunset -- Current Law Reversion

Under IRC 164(b)(6) as amended by OBBBA, the elevated SALT cap and its annual inflation adjustments apply for tax years 2025 through 2029. Beginning on January 1, 2030, the SALT deduction cap reverts to $10,000 ($5,000 for married filing separately) under current enacted law. This is not speculative; it is the text of the statute as enacted. The reversion occurs automatically on January 1, 2030, unless Congress legislates to prevent it.

Why Practitioners Must Flag the Sunset Now

The gap between a $40,000-plus SALT cap in 2029 and a $10,000 cap in 2030 is material for high-income clients in high-tax states. The practical impact is that decisions made today on the assumption of an elevated SALT cap (such as how much state income tax to pay in 2029, whether to accelerate deductions before 2030, or whether to make PTET elections for years through 2029) should be modeled under both the current-law reversion scenario and a legislative-extension scenario. Relying on the elevated cap beyond 2029 without a legislative change is a planning assumption, not a legal conclusion.

Congress Has Acted Before; It May Act Again

The legislative history of the SALT cap demonstrates that it has been a recurring target for amendment. The TCJA enacted the $10,000 cap as a temporary provision with a 2025 sunset; Congress extended and then raised it through OBBBA. The OBBBA itself includes a 2030 sunset. Given the political salience of the SALT cap, it is reasonable to flag for clients that Congress may again act before the 2030 reversion date. However, practitioners should not advise clients to rely on a legislative extension that has not yet been enacted. Advise based on current law; flag the possibility of legislative change as a planning contingency to monitor.

Frequently Asked Questions

Common questions from enrolled agents, CPAs, and tax attorneys on the IRC 164 SALT cap, the OBBBA increase, and the PTET bypass.

Related Practitioner Guides

The following guides cover OBBBA provisions and related tax rules that practitioners should consider alongside the IRC 164 SALT cap analysis.

• OBBBA Vehicle Loan Interest Deduction Practitioner Guide -- Above-the-line deduction for new U.S.-assembled vehicle loan interest under OBBBA; MAGI phaseout, Schedule 1-A, and open proposed-reg questions.
• IRC 24 Child Tax Credit OBBBA Guide -- taxpayers above the IRC 164(b)(6) SALT phase-down threshold also typically face the IRC 24 CTC phase-out; both provisions are individual-level MAGI-based limitations analyzed together for high-income families.
• IRC 163(j) Business Interest Limitation Guide -- pass-through entity owners who elect PTET to bypass the SALT cap often also carry business debt subject to IRC 163(j); practitioners should model both the PTET deduction and the IRC 163(j) business interest limitation for the same pass-through entity in the same engagement.
• Section 409A Nonqualified Deferred Compensation Guide -- high-income executives subject to the SALT phase-down often have nonqualified deferred compensation (NQDC) arrangements under Section 409A; deferral elections affect MAGI, which in turn affects where the executive falls on the SALT phase-down curve; practitioners should coordinate the 409A deferral analysis with the SALT cap analysis.
• IRC 461(l) Excess Business Loss Limitation Guide -- the IRC 461(l) excess business loss limitation applies at the individual level and affects the federal income base to which the individual's SALT deduction is ultimately applied; practitioners handling high-income pass-through entity owners should analyze the IRC 461(l) limitation alongside the SALT cap in the same engagement.
• Form 709 Gift Tax Return Guide -- high-income individuals above the SALT phase-down threshold are typically active gift-tax filers; the same income and wealth levels that create SALT phase-down exposure also drive gift-tax planning needs, and the two areas of practice frequently arise in the same client engagement.
• IRC 55 and Form 6251: Individual Alternative Minimum Tax Guide -- the OBBBA permanent SALT cap under IRC 164(b)(6) eliminates or reduces the state income tax deduction that previously moderated AMTI exposure; high-income taxpayers who lose the SALT deduction under IRC 164(b)(6) and also have ISO exercises, accelerated depreciation, or other AMTI preference items face compounded AMT exposure; practitioners should run the IRC 55 Form 6251 computation alongside the IRC 164 SALT analysis for all high-income individual clients.

Tax Software for Complex Individual and Pass-Through Returns

Americas Tax has supported enrolled agents, CPAs, and tax attorneys handling high-income individual returns, Schedule A SALT planning, PTET analysis, and OBBBA compliance since 2001. Our team understands the Schedule A workflow, the PTET bypass mechanics, and the phase-down computations practitioners face in 2025 and beyond.