Eight statute-pinned PTET scenarios
Each example is reproduced to the dollar against the relevant state Department of Revenue primary source. They serve two purposes: (1) you can sanity-check the picker engine against published guidance, and (2) you can use any one as a template for your own pass-through structure. The fixture suite is run at build time; see methodology for the reproduction proof.
California — single-owner S-corp with $500,000 qualified net income
A CA single-owner S-corp with $500,000 of qualified net income elects PTET. Entity pays $46,500 (9.3% × $500K) to FTB. At a 37% federal bracket, the entity-level deduction saves $17,205 in federal tax. After QBI offset (~20% × 37%), net benefit is ~$13,764 — versus zero deduction without the election (SALT cap blocks personal-tax deduction).
Owner federal bracket: 37%. Entity type: s-corp. Owners: 1. Net of §199A QBI offset (~$3,441), aggregate net benefit is approximately $13,764.
New York — partnership with $1,000,000 qualified net income (graduated rates)
A NY partnership with $1M of qualified net income elects PTET. The first $2M of pool income is taxed at 6.85% — so all $1M here falls in the lowest graduated bracket. Entity pays $68,500 to NYDTF. At 37% federal bracket the deduction saves $25,345; net of QBI offset, ~$20,276.
Owner federal bracket: 37%. Entity type: partnership. Owners: 2. Net of §199A QBI offset (~$5,069), aggregate net benefit is approximately $20,276.
New York — S-corp with $10,000,000 qualified net income (3-bracket walk)
A NY S-corp with $10M of qualified net income walks three brackets: $137K at 6.85% on the first $2M, $289.5K at 9.65% on the next $3M, $515K at 10.30% on the next $5M — total $941,500. Federal deduction at 37% is $348,355. Picker uses the actual NY rate schedule (engine ./rate-schedules.ts).
Owner federal bracket: 37%. Entity type: s-corp. Owners: 1. Net of §199A QBI offset (~$69,671), aggregate net benefit is approximately $278,684.
Illinois — multi-member LLC with $2,000,000 qualified income
An IL multi-member LLC (taxed as partnership) with $2M of qualified income elects PTET. Entity pays $99,000 (4.95% flat × $2M). Federal deduction at 37% is $36,630. Owners receive a refundable IL credit equal to the $99K paid.
Owner federal bracket: 37%. Entity type: llc-as-partnership. Owners: 4. Net of §199A QBI offset (~$7,326), aggregate net benefit is approximately $29,304.
NY State + NYC PTET stacked — partnership with $2,000,000 NYC-source income
An NYC-source partnership stacks both elections. NY State PTET on $2M at the lowest bracket (6.85%) is $137,000. NYC PTET (3.876% flat) on the same $2M is $77,520. Combined entity-level tax: $214,520. Combined federal deduction at 37%: $79,372. The picker's stacking-hint feature flags this combination automatically.
Owner federal bracket: 37%. Entity type: partnership. Owners: 1. Net of §199A QBI offset (~$15,874), aggregate net benefit is approximately $63,498.
New Jersey — S-corp with $3,000,000 BAIT-eligible income (2-bracket walk)
NJ BAIT graduated rates walk three brackets on $3M: $14,187.50 at 5.675% on the first $250K, $48,900 at 6.52% on the next $750K, and $182,400 at 9.12% on the next $2M — total $245,488. Federal deduction at 37%: $90,830. NJ BAIT was the earliest enacted PTET regime (2020).
Owner federal bracket: 37%. Entity type: s-corp. Owners: 1. Net of §199A QBI offset (~$18,166), aggregate net benefit is approximately $72,664.
Massachusetts — partnership with $500,000 qualified taxable income
A MA partnership with $500K of qualified taxable income elects the PTE excise. Entity pays $25,000 (5% flat × $500K). Federal deduction at 37% saves $9,250. Owners receive a 90% refundable credit ($22,500) against MA personal income tax.
Owner federal bracket: 37%. Entity type: partnership. Owners: 2. Net of §199A QBI offset (~$1,850), aggregate net benefit is approximately $7,400.
Tri-state allocation — CA $400K + NY $400K + IL $200K
A three-state allocation across CA / NY / IL. Each state computes independently; only the federal-bracket arbitrage at 37% aggregates. Total entity-level tax $74,500; total federal deduction $27,565. Net of QBI offset (~$5,513): aggregate net benefit ~$22,052. NY is in the first graduated bracket (6.85%).
Owner federal bracket: 37%. Entity type: llc-as-partnership. Owners: 3. Net of §199A QBI offset (~$5,513), aggregate net benefit is approximately $22,052.
Honesty pass
The picker engine reproduces each totalEntityTax and totalFederalDeductionfigure above to within $1. Differences of cents are floating-point rounding; the engine's validateAllFixtures() helper asserts these at build time. The §199A QBI offset shown in narratives is a uniform 0.20 × bracket × entityTaxheuristic; real-world owners below the §199A SSB threshold or in specified-service-trades may see different offsets — consult your CPA.