Citation manifest

Federal anchors

• IRC §164(b)(6) — Limitation on individual deductions for state and local taxes (the TCJA SALT cap)
  Originally $10,000 joint/single ($5,000 MFS) under TCJA (2017). OBBBA July 2025 raised the cap to ~$40,000 joint with a $500,000 MAGI phaseout to a $10,000 floor for tax years 2025–2029; cap reverts to $10,000 in 2030. PTET workaround explicitly preserved by OBBBA. Re-verify legislative text at every annual content review.
• IRS Notice 2020-75 — Federal deduction blessing for entity-paid state PTET
  Treasury / IRS confirmed that entity-level state taxes paid by a partnership or S-corp are deductible at the entity level for federal purposes — the structural foundation for every state PTET regime.
• IRC §199A — Qualified Business Income (QBI) deduction (20% deduction)
  PTET reduces the §199A QBI base proportionally because the federal deduction at the entity level lowers the qualified business income that flows through to owners. The federal SALT-arbitrage benefit must be netted against the QBI offset.

Per-state primary sources (verified states)

Cross-check references (NEVER cite as primary)

• CBIZ — Pass-Through Entity Tax: State Election Dates
  Used to identify which states have enacted PTET. Never used to pin a per-state datum.
• EisnerAmper — State PTET Updates
  Same role: enactment cross-check, not citation source.

OBBBA July 2025 (re-verify at annual review)

The One Big Beautiful Bill (signed July 2025) raised the SALT cap mechanics for tax years 2025–2029 and preserved PTET workaround. Legislative text re-verification at every annual content review — 2027 reconciliation may alter the floor, phaseout, or sunset date.