The formulas
- Excess = (taxable income before the limit + itemized deductions) - start of the 37% bracket
- Reduction = 2/37 x lesser of itemized deductions or excess
- 2026 starts: $640,600 single and head of household, $768,700 joint, $384,350 separate
How it works
Section 68 as rewritten by the One Big Beautiful Bill Act reduces itemized deductions by 2/37 of the lesser of the deductions or the amount by which taxable income, before the limit and increased by itemized deductions, exceeds the start of the 37% bracket. It applies to tax years beginning after December 31, 2025, after every other limit on itemized deductions.
Publication 505 for 2026 describes the same cut as 5.4% and lists the bracket starts from Rev. Proc. 2025-32. The effect is to cap the value of each itemized dollar at 35 cents for taxpayers in the top bracket.
Illustrative figures only. Check the result against your firm's methodology before relying on it.
Common questions
Does it affect the QBI deduction?
Publication 505 states the limitation does not apply when figuring the QBI deduction.
Is it the old Pease limit?
No. Pease used 3% of AGI over a threshold. This rule uses 2/37 tied to the 37% bracket.
What if I take the standard deduction?
The rule applies only to itemized deductions.
Sources
- 26 U.S.C. 68, Overall limitation on itemized deductions (LII)
- IRS Publication 505 (2026), Tax Withholding and Estimated Tax
- IRS Rev. Proc. 2025-32, 2026 inflation-adjusted items (IRB 2025-45)
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