As the House and Senate continue negotiations over the “One Big Beautiful Bill,” a significant development is sending ripples through the small business and tax advisory community: Republicans are aiming to restrict SALT cap workarounds used by pass-through entities, a move that could generate up to $20 billion annually in additional tax revenue.
But for CPAs, tax attorneys, and wealth advisors, this change could mean major year-end planning shifts and more exposure for high-income clients in high-tax states.
Under the 2017 Tax Cuts and Jobs Act (TCJA), individuals could only deduct up to $10,000 in state and local taxes on their federal returns. To bypass this limit, over 36 states adopted Pass-Through Entity (PTE) taxes—a workaround allowing owners of partnerships and S corporations to pay state income tax at the entity level, thus making the deduction fully available at the federal level.
This workaround has been a lifeline for high earners and small business owners in states like California, New York, Illinois, and New Jersey, where state tax burdens are among the highest in the nation.
Both the House and Senate bills seek to limit or eliminate this workaround in different ways:
The stated goal: close “loopholes” and prevent what lawmakers call a “backdoor repeal” of the SALT cap.
For CPA firms and tax planners, this move has far reaching implications:
This provision may not make the headlines, but it’s one of the most consequential tax changes for the small business sector in the bill.
The proposed SALT restriction changes are especially relevant because:
In short: what happens in the next two weeks could determine how business owners structure and deduct their income for the next five years.
Bizora AI tracks state-by-state PTE laws, models the impact of federal deduction limits, and generates real-time client memos for your firm to send before the rules change.
Need to see how the SALT workaround rollback affects your clients in New York or California?→ Ask Bizora AI for instant, state-specific analysis with citations.