• videocam Live Webinar with Live Q&A
  • calendar_month August 18, 2026 @ 1:00 p.m. ET/10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Corporate Tax
  • schedule 110 minutes

State Pass-Through Entity Taxation Regimes After OBBBA: Reevaluating PTE Elections

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About the Course

Introduction

This webinar will analyze state pass-through entity (PTE) tax regimes and the evolving considerations for making entity-level tax elections in light of significant federal tax changes. Our panel of knowledgeable state and local tax (SALT) practitioners will examine when PTE elections enhance federal and state tax outcomes—and when they may create unintended consequences—through detailed, practitioner-focused case studies.

Description

State PTE regimes were widely adopted as a workaround to the $10,000 federal limitation on individual SALT deductions enacted under the Tax Cuts and Jobs Act (TCJA). However, the One Big Beautiful Bill Act, enacted July 4, 2025, materially altered this landscape by increasing the SALT deduction cap to $40,000 (subject to income-based phaseouts beginning at $500,000). As a result, many taxpayers can now obtain significantly greater SALT deductions at the individual level, fundamentally changing the cost-benefit analysis that historically drove PTE elections. 

However, PTE tax regimes still benefit owners with income over the $500,000 threshold and those with SALT deductions over the $40,000 cap. Businesses that consistently pay significant state taxes and those with significant income in a particular year still benefit from state PTE relief. 

Many state PTE regimes were scheduled to sunset after TCJA. Additionally, several states have revised their policies for taking a SALT deduction at the entity level. State and local tax advisers need to reconsider taking SALT deductions at the entity level to maximize deductions for businesses and their owners.

Listen as our panel of experienced state and local tax professionals addresses recent state PTE developments and new considerations stemming from the increase in the SALT cap. 

Presented By

Kimberly Capizzi, CPA
Director
Miller Cooper & Co., Ltd.

Ms. Capizzi is a Tax Director at Miller Cooper, specializing in state and local tax planning and compliance for multistate businesses. She advises clients on a full range of SALT services, including tax planning, compliance reviews, audit representation, and tax mitigation strategies. Ms. Capizzi works extensively with complex, multi-tiered partnerships and flow-through entities, ensuring compliance across jurisdictions and identifying opportunities for long-term tax savings. She also assists businesses with structural enhancements, mergers and acquisitions, due diligence and state tax controversy matters. Ms. Capizzi's experience spans Fortune 1000 companies and mid-sized businesses in industries such as manufacturing, retail, professional services, real estate, private equity and technology.

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Richard Spengler
Washington National Tax Principal; State & Local Tax Technical Practice Leader
BDO USA

Mr. Spengler is a Principal in BDO's Washington National Tax office, and the State & Local Tax Services Technical Practice Leader. He is responsible for advising the firm on the application of ASC 740 and ASC 450 to state tax issues. Mr. Spengler's focus is in the areas of state income/franchise taxes, sales/use tax and tax restructuring. He also has significant experience in the design and implementation of legal entity structures that are more tax efficient. He provides support to BDO’s Transaction Advisory Services group on state tax issues that arise on transaction deals. Mr. Spengler also has significant experience with the analysis of tax return positions. He has had a great deal of success with securing significant refunds for clients related to gray and misunderstood areas of the tax law.

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Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Tuesday, August 18, 2026

  • schedule

    1:00 p.m. ET/10:00 a.m. PT

I. Background

II. Recent federal legislative changes

III. Mandatory PTE taxation

IV. Elective PTE taxation

V. Specific state taxation regimes

VI. Recent developments in specific states' PTE regimes

VII. Analyzing the impact of PTE taxation on owners

VIII. Best practices

The panel will cover these and other critical issues:

  • Reassessing PTE elections following the increase in the SALT deduction cap to $40,000
  • Impact of suspended losses, basis limitations, and at-risk rules on PTE benefits
  • Planning for partnerships with trust, individual, and tiered entity owners
  • State-by-state differences in credits, deductions, and elective versus mandatory regimes

Learning Objectives

After completing this course, you will be able to:

  • Identify situations where state PTE tax elections should be avoided
  • Ascertain how the OBBBA impacts the decision to deduct SALT at the entity level
  • Decide which states recently updated the requirements for deducting state taxes at the entity level
  • Determine the interaction of the federal PTE tax deduction and the business interest limitation of IRC 163(j)


  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of SALT taxation, nexus and apportionment as it applies to multi-state businesses.

BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .