If you’re an investor, small business owner, or high-net-worth individual, you’ve likely heard about the Tax Cuts and Jobs Act (TCJA) of 2017—and that several provisions sunset after 2025. What you may not realize is how local market factors and investor behavior will shape who benefits (or loses) most. Below, we provide both a hyperlocal lens—with examples spanning high-tax states, low-tax states, and Opportunity Zones—and deeper strategy recommendations so you can stay ahead of the curve.
Quick Timeline of Key TCJA Changes
Year / Milestone
Event
2017 (TCJA Enacted)
Top individual rate dropped to 37%, corporate rate set at 21%, SALT deductions capped at $10k, and the 20% QBI deduction added.
2023–2025 (Phase-Outs)
Bonus depreciation starts stepping down (100% → 80% → 60%), prompting some businesses to accelerate capital purchases.
End of 2025 (Sunset)
Key provisions expire: Top rate reverts to 39.6%, QBI deduction ends, SALT cap lifted, estate/gift exemption shrinks, etc.
2026 (New Era Begins)
Unless Congress intervenes, individual rates and deductions generally revert to pre-2018 rules.
What’s Happening With the 2025 TCJA Expirations?
Under the TCJA, certain individual and business tax breaks were temporary. They automatically revert if Congress does not renew or modify them:
Individual Rate Increases
The top individual rate of 37% reverts to 39.6%, and middle tax brackets will also inch upwards.
The $10,000 SALT deduction cap is slated to end bipartisanpolicy.org, potentially allowing larger deductions in high-tax states like California, New York, or New Jersey.
Estate & Gift Threshold Drop
The estate and gift tax exemption (around $13.6 million per individual in 2025) shrinks to roughly $7 million in 2026 warrenaverett.com.
Bonus Depreciation Phase-Out
Bonus depreciation is already stepping down each year, affecting capital-intensive industries like manufacturing and technology. By 2027, it drops to 0%warrenaverett.com.
Unless Congress intervenes with an extension, modification, or new legislation, these changes take effect January 1, 2026.
Hyperlocal Examples: High-Tax vs. Low-Tax States
California, New York, New Jersey (High-Tax States)
SALT Cap Sunset Advantage: Lifting the $10k SALT cap could allow homeowners to deduct tens of thousands in property and state income taxes, substantially reducing federal taxable income.
Real Estate Impact: In Los Angeles County, where property taxes and local surcharges can exceed $20k annually, dropping the SALT cap can make high-end real estate more appealing to buyers who factor in tax deductions.
Investor Behavior: Advisors in these states report an uptick in Roth IRA conversions and estate planning as wealthy families try to lock in benefits before rates revert.
Texas or Florida (Low-Tax States)
Minimal SALT Effect: Because state income taxes are already low or nonexistent, the SALT cap hasn’t been a major burden.
Population & Demand: Cities like Austin or Miami often see inflows of residents fleeing high-tax regions. Even if the SALT cap ends, many new arrivals may still choose to stay for business-friendly policies and cost-of-living advantages.
Opportunity Zones (e.g., Atlanta Westside, Denver Metro)
Capital Gains Deferral Incentives: Opportunity Zones offer capital gains deferral or partial forgiveness for investments that meet certain requirements.
Recent Data: In Atlanta’s Westside, Opportunity Zone investments have increased by about 15% since 2018, potentially accelerating further if investors seek new ways to offset higher post-2025 tax rates or reduce capital gains file-2p1vnpe7kgkqn7vu6twc37.
Long-Term Outlook: Even as federal tax policies shift, these zones may attract capital for real estate, small business development, and other projects, given their unique incentives.
How Could This Affect Different Asset Classes?
Manufacturing & Technology
The bonus depreciation phase-out hits these sectors hardest, as large capital expenditures become less tax-efficient. Expect potential slowdowns in equipment upgrades after 2026.
Retail & Consumer Goods
Middle-income households facing higher rates in 2026 may cut discretionary spending, hurting these sectors. Small retailers might need to pivot to value-driven or discount models.
Commercial Real Estate
In high-tax states, a SALT cap sunset could drive renewed interest in commercial properties. Meanwhile, losing QBI could raise effective tax rates for pass-through landlords, especially in mid-tier markets.
Residential Real Estate
Higher-income buyers might flock to markets where bigger itemized deductions (property taxes, mortgage interest) become more valuable.
Diving Deeper into Investor Strategies
C-Corp Conversions: Benefits & Trade-Offs
If you’re a small business owner operating as an LLC or S-Corp, the loss of the 20% QBI deduction could raise effective taxes by up to 10 points. A C-Corp, by contrast, benefits from a flat 21% federal corporate tax rate file-2p1vnpe7kgkqn7vu6twc37.
Case Study:
Before 2026: A pass-through entity with $500k net income might pay around ~30% after factoring in the QBI deduction.
After 2026 (QBI Ends): The owner’s top rate jumps to nearly 40%.
Converting to a C-Corp: Profit retained within the corporation (not distributed as dividends) stays taxed at 21%. The downside? Dividends face a second level of taxation, but if the aim is to reinvest earnings, it might still be a win.
Estate Planning: Irrevocable Trusts & Family Limited Partnerships
With the estate tax exemption plunging from $13.6M to around $7M, more families risk estate tax exposure.
Irrevocable Trusts: Assets moved into irrevocable trusts are generally excluded from your estate, shielding future appreciation from estate taxes.
Family Limited Partnerships (FLPs): You can transfer ownership interests (at a possible valuation discount) to heirs while retaining some control. As one estate attorney notes, trust formations are up 30% this year from clients wanting to lock in the current exemption.
Bonus Depreciation Timing
Capital-Intensive Industries: If you plan major purchases—like manufacturing equipment or data center servers—do so before the bonus depreciation fully phases out (sliding from 80% in 2023 to 20% by 2026).
Real Estate Depreciation: Cost-segregation strategies can accelerate building component write-offs, but they become less powerful without full bonus depreciation.
Investor Behavior & Trends
Financial Advisors in high-tax states report increased demand for:
Estate Planning: Especially among families with estates valued between $7M and $15M, as they rush to utilize the larger exemption.
Roth Conversions: Individuals wanting to lock in lower rates on retirement account conversions before top rates climb back toward 40%.
SALT Workarounds: Many are also eyeing Pass-Through Entity (PTE) tax elections, but these might be less vital if the SALT cap truly lifts.
Potential Legislative Paths & Uncertainty
While the January 1, 2026, deadlines loom, there’s no guarantee the changes will happen exactly as written:
Full Expiration: If no legislative action is taken, all temporary TCJA provisions expire.
Partial Extensions: Congress could retain popular items (like the QBI deduction) but let others lapse, or modify the SALT cap.
Bipartisan Compromises: Certain senators have signaled interest in extending the QBI deduction or partially raising the SALT cap limit file-2p1vnpe7kgkqn7vu6twc37.
Investor Takeaway: Stay agile. Even if changes look likely, a last-minute congressional deal could shift your best strategy.
Comparing Pre-TCJA, TCJA-Era, and Post-2025 Rates
Tax Provision
Pre-TCJA (2017)
TCJA-Era (2018–2025)
Post-2025 (Projected)
Top Individual Rate
39.6%
37%
39.6% + 3.8% NIIT (for high earners)
Corporate Rate
35%
21% (Permanent)
21% (No change unless new legislation)
QBI Deduction
N/A
20% deduction on pass-through profits
Expires—no QBI deduction (unless extended by Congress)
SALT Deduction
Unlimited (but rarely used)
Capped at $10k
Cap expires—high-tax states regain full SALT itemization
Estate & Gift Exemption
$5.49M per individual
~$13.6M in 2025 (inflation adjusted)
~$7M in 2026 (inflation adjusted)
Bonus Depreciation
50%
100% in 2017–2022, now phasing to 0%
0% by 2027
Practical Steps to Take Right Now
Evaluate Business Structure
S-Corp/LLC → C-Corp: Run the numbers on effective tax rates post-2025 if you plan to retain earnings in the company.
Accelerate or Defer Income/Expenses
Pull Income into 2025 if rates will be higher later.
Push Big Deductions into 2026 to offset those higher rates.
Plan Estate Moves
Set Up Trusts, FLPs: If you’re near $7M in net worth, act before the exemption drops.
Leverage Opportunity Zones
For capital gains deferral, check designated Opportunity Zones in markets like Atlanta’s Westside or Denver Metro, which continue to see growth.
Monitor Legislative Developments
Stay alert for possible partial extensions or SALT modifications; your plan may need quick adjusting.
Where Are the Opportunities?
High-Tax States (Post-SALT Cap): If the cap lifts, states like California or New York could see a resurgent property market as buyers factor in bigger itemized deductions.
Low-Tax States: Even if SALT changes reduce some tax advantage, strong population growth and business-friendly policies keep markets like Texas and Florida appealing.
Estate Planning Firms & Advisors: Demand for strategic services is rising as individuals position themselves before 2026.
Conclusion: Turning Potential Challenges Into Opportunities
The expiration of key TCJA provisions will reshape the tax landscape in 2025, but the effects differ drastically based on geography and investor profile. High-tax states stand to regain valuable deductions, while pass-through businesses may lose out. At the same time, capital-intensive industries and real estate investors must navigate the end of bonus depreciation and the QBI deduction.
Stay Engaged
Track potential legislative deals—partial extensions could keep some perks alive.
Connect with local and national advisors who can help you interpret evolving tax policy in real time.
How Activazon Can Help
By joining Activazon’s waitlist, you’ll gain access to real-time insights on how these federal changes intersect with regional market conditions—from SALT cap shifts in Los Angeles to Opportunity Zone growth in Atlanta. Our data-driven platform assists investors in making timely, well-informed decisions.
Note: This content is for informational purposes only and does not constitute legal or financial advice. Always consult a qualified professional to tailor strategies to your individual circumstances.