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Where individual, corporate, and passthrough entity taxation meet By Mo Bell-Jacobs, J.D.; Bridget McCann, CPA; and Steve Wlodychak, J.D., LL.M. Related Editor: Bridget McCann, CPA By now, most practitioners are well aware of the annual limitation enacted by the law known as the Tax Cuts and Jobs Act (TCJA), P.L. 115-97, in 2017 that limits the amount of state and local taxes individuals can deduct for federal income tax purposes to not more than $10,000 ($5,000 in the case of a married individual filing a separate return) (the SALT cap). 1 No doubt most are also aware of the ensuing legislation at the state level to offer taxpayers a workaround to the SALT cap by enacting passthrough-entity-level taxes, which arguably impose the tax liability for owners of passthrough entities (PTEs) (such as partnerships, LLCs treated as partnerships, and S corporations) instead directly on the PTE.

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