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The $10,000 SALT Cap is Dead: 5 Itemized Deduction Strategies for 2026

October 11, 2026
9 min read
Tax Planning
The $10,000 SALT Cap is Dead: 5 Itemized Deduction Strategies for 2026
On this page
  1. 1. The Great Reset: Understanding the 2026 SALT Sunset
  2. 2. The PTET Power Play: Bypassing the Cap Before 2026
  3. 3. Strategic "Bunching" for the 2026 Tax Year
  4. 4. Mortgage Interest: The $1 Million Return
  5. 5. Cross-Border Coordination: SALT and the Foreign Tax Credit
  6. Common Mistakes to Avoid
  7. Frequently Asked Questions
  8. Ready to Optimize Your 2026 Tax Strategy?

If you are a small business owner in a high-tax state like California, New York, or New Jersey, you have likely spent the last seven years feeling the sting of the $10,000 State and Local Tax (SALT) cap. According to the IRS Statistics of Income (SOI) Bulletin, the number of taxpayers claiming itemized deductions plummeted from 46.5 million in 2017 to just 18.0 million in 2018—a direct result of the Tax Cuts and Jobs Act (TCJA). For many of our clients at Zenith Financial Advisors, this cap felt less like a policy and more like a penalty on success. But the landscape is about to shift dramatically. On December 31, 2025, the SALT cap is legally scheduled to sunset. As we look toward the 2026 tax year, the "death" of the $10,000 limit opens a massive window for strategic planning. If you aren't preparing now to pivot your deduction strategy, you are leaving thousands of dollars on the table. Our team has identified five core strategies to help you navigate this transition and potentially slash your effective state tax burden by 35% or more.

Key Takeaways

  • The $10,000 SALT cap expires after 2025, allowing for full state and local tax deductions in 2026 under current law.
  • Small business owners can utilize Pass-Through Entity Tax (PTET) elections now to bypass the cap even before the sunset.
  • Strategic "bunching" of expenses into the 2026 tax year will maximize the impact of your itemized deductions.
  • The return of the $1 million mortgage interest debt limit (up from $750,000) provides additional tax relief for homeowners.
  • Cross-border entrepreneurs must carefully coordinate SALT deductions with Foreign Tax Credits to avoid double taxation.

1. The Great Reset: Understanding the 2026 SALT Sunset

The Tax Cuts and Jobs Act of 2017 introduced the $10,000 limit on itemized deductions for state and local taxes, encompassing property taxes and either income or sales taxes. For high-earning business owners, this was a significant blow. However, per the legislative text of the TCJA, these individual income tax provisions are temporary. Unless Congress acts to extend them, the rules revert to the 2017 status quo on January 1, 2026.

According to the Tax Foundation, the expiration of these provisions will lead to a broader tax base but also the return of significant deductions that were previously suppressed. In 2026, the standard deduction is expected to be cut roughly in half (adjusted for inflation), making itemizing a much more attractive option for most business owners. We anticipate that for a business owner earning $400,000 in a state with a 9% tax rate, the ability to deduct the full $36,000 in state income tax—plus property taxes—could represent a federal tax savings of over $8,000 compared to the capped years.

As we counsel our clients, it is vital to remember that this isn't just about "waiting for 2026." It is about positioning your liquidity and business structure now. We are currently reviewing client portfolios to ensure that large state tax payments scheduled for late 2025 are, where legally permissible, shifted into early 2026 to capture the full deduction power.

Source: IRS.gov - SOI Tax Stats

2. The PTET Power Play: Bypassing the Cap Before 2026

While we wait for the 2026 sunset, many small business owners are already winning the SALT war through the Pass-Through Entity Tax (PTET). This is a state-level workaround that the IRS officially blessed in Notice 2020-75. This notice clarifies that state and local income taxes imposed on and paid by a partnership or an S corporation on its income are allowed as a deduction by the entity in computing its non-separately stated income or loss.

Essentially, the PTET turns a personal itemized deduction (which is capped) into a business expense (which is not). According to data from the Tax Foundation, 36 states plus New York City have enacted PTET legislation as of 2024. If you operate as an S-Corp or a Partnership, your entity can pay the state income tax on your behalf. The entity gets a full federal deduction, and you receive a credit on your state tax return for the taxes paid by the entity.

Feature Personal SALT Deduction (Capped) PTET Strategy (Uncapped)
Federal Limit $10,000 No Limit (Business Expense)
Eligibility Individuals S-Corps, Partnerships, LLCs Impact on AGI No effect (Below the line) Reduces AGI (Above the line)

For cross-border owners, the PTET is particularly complex. If you are a US citizen living in Canada and running a US-based S-Corp, paying the PTET might affect your Foreign Tax Credit (FTC) calculations on Form 1116. Our team at Zenith specializes in ensuring that these "workarounds" don't inadvertently create a tax liability on the Canadian side of the border.

Source: IRS Notice 2020-75

3. Strategic "Bunching" for the 2026 Tax Year

One of the most effective strategies we employ at Zenith is "deduction bunching." Since the standard deduction is slated to drop significantly in 2026, many taxpayers who currently take the standard deduction will find themselves back in the "itemizing" category. To maximize this, we recommend pushing discretionary deductible expenses from 2025 into 2026.

Consider a scenario where you have significant medical expenses or are planning a large charitable contribution. If you pay those in 2025, they may provide zero tax benefit because your total itemized deductions (including the $10,000 SALT cap) don't exceed the high 2025 standard deduction ($30,000 for married filing jointly). However, by moving those payments to January 2026, you combine them with a now-uncapped SALT deduction and a lower standard deduction threshold. This creates a "super-deduction" year.

According to official IRS guidance in Publication 17, expenses are generally deductible in the year they are paid. For small business owners, this bunching also applies to state estimated tax payments. While you cannot prepay 2026 taxes in 2025 to bypass the cap, you can certainly ensure that your final 2025 state estimated payment (usually due Jan 15, 2026) is made in 2026 rather than December 2025. This ensures the payment falls into the uncapped year.

PRO TIP: The 4th Quarter Shift

Most taxpayers reflexively pay their Q4 state estimates in December to "get it over with." If you are a high-income earner, hold that payment until January 2026. Under the current sunset schedule, that payment will be fully deductible on your 2026 federal return, whereas in December 2025, it would likely be trapped under the $10,000 cap and provide no federal benefit.

4. Mortgage Interest: The $1 Million Return

The SALT cap wasn't the only restriction the TCJA placed on homeowners. It also lowered the limit on deductible mortgage interest from $1 million of acquisition indebtedness to $750,000. For our clients in premium markets like Seattle, Vancouver (US citizens), or San Francisco, this was a massive reduction in deductible interest.

When the TCJA expires, the limit is scheduled to return to $1 million for debt incurred after December 31, 2025. Furthermore, the deduction for home equity line of credit (HELOC) interest—which was largely eliminated unless the funds were used to improve the home—may also see a return to more lenient pre-TCJA standards. Per IRS Publication 936, mortgage interest remains one of the most powerful tools for reducing taxable income for those who itemize.

For the self-employed professional, this is a double win. If you have a home office, you are already deducting a portion of your mortgage interest as a business expense on Form 8829. The return of the $1 million limit for personal itemized deductions allows you to capture more of the remaining interest that isn't allocated to the business, further driving down your effective tax rate. We recommend reviewing any planned refinancing or new property acquisitions with 2026 in mind to maximize these interest deductions.

Source: IRS Publication 936

5. Cross-Border Coordination: SALT and the Foreign Tax Credit

For our cross-border small business owners, the SALT cap expiration creates a unique interaction with international tax law. If you are a US citizen living in Canada, you are likely already paying high Canadian taxes. Under IRS Form 1116, you can claim a Foreign Tax Credit (FTC) to prevent double taxation on your US return.

However, many expats also maintain a US presence or property, incurring state taxes. The interaction between itemized SALT deductions and the FTC is a balancing act. If you itemize SALT deductions on your US return, you reduce your US taxable income, which can actually reduce the amount of Foreign Tax Credit you can utilize in the current year, potentially leading to excess credits that must be carried forward.

Per Canada Revenue Agency (CRA) guidelines and the US-Canada Tax Treaty, we must also ensure that state-level tax planning doesn't create "mismatched" income. For example, some Canadian provinces do not recognize the US S-Corp as a flow-through entity in the same way the IRS does. When the SALT cap dies, the increased federal deduction in the US may widen the gap between your US and Canadian taxable income. Our team focuses on harmonizing these two systems to ensure that a win on the US SALT side doesn't lead to a loss in Canadian tax efficiency.

Source: Canada.ca - Foreign Tax Credits

Common Mistakes to Avoid

  • Ignoring the Alternative Minimum Tax (AMT): Even if the SALT cap expires, the AMT remains a "shadow tax" that often disallows state tax deductions for high earners. If the pre-TCJA AMT rules also return, the benefit of the SALT cap removal could be partially offset. Always run a dual-scenario projection.
  • Missing PTET Election Deadlines: Most states require you to opt into the PTET by a specific date (often March 15 for calendar-year S-Corps). If you miss the window, you are stuck with the $10,000 cap for that tax year regardless of your income.
  • Overlooking Sales Tax: In states with no income tax (like Washington or Florida), you can deduct state sales tax instead. With the cap removed in 2026, keeping receipts for major business purchases or using the IRS optional sales tax tables becomes significantly more valuable.
  • Failing to Coordinate with Canada: For cross-border owners, claiming a massive SALT deduction in the US might lower your US tax below the level of your Canadian tax credits, resulting in "wasted" credits if not planned properly.

Frequently Asked Questions

Will Congress extend the SALT cap before it expires?

This is the multi-billion dollar question. While there is political pressure from both sides to either eliminate or extend the cap, current law mandates its expiration on Dec 31, 2025. We advise our clients to plan based on existing law while maintaining the flexibility to pivot if new legislation is signed.

Can I deduct state taxes paid on my business income?

Currently, if you are a sole proprietor (Schedule C), state income taxes are considered a personal expense subject to the $10,000 cap. Only through a PTET election (available to S-Corps and Partnerships) can you currently deduct these at the business level. After 2025, they will be deductible on Schedule A without the $10,000 limit.

What is the $10,000 FBAR threshold and does it relate to SALT?

The FBAR (Report of Foreign Bank and Financial Accounts) threshold is $10,000 in aggregate across all foreign accounts at any point in the year. While it doesn't directly relate to the SALT cap, both are critical for cross-border compliance. According to FinCEN, over 1.4 million FBARs are filed annually, and penalties for non-compliance can be draconian, regardless of your SALT deduction status.

How does the SALT cap affect my Canadian tax return?

It doesn't directly affect your Canadian return, as the CRA doesn't allow a deduction for US state taxes. However, it affects the "foreign tax paid" amount you report to the IRS, which changes your US tax liability and, consequently, how much Canadian tax you can use as a credit against your US bill.

Ready to Optimize Your 2026 Tax Strategy?

Don't let the expiration of the TCJA catch you off guard. Our cross-border experts are ready to help you navigate the end of the SALT cap and maximize your deductions.

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