Skip to content

California mortgage interest uses the federal $750,000 limit instead of California's $1,000,000 + $100,000 #10216

Open

Description

@curielmc

Title: California mortgage interest uses the federal $750,000 limit instead of California's $1,000,000 + $100,000

Problem

ca_itemized_deductions_pre_limitation takes mortgage interest from the federal interest_deduction, so it inherits the TCJA limit in 26 U.S.C. 163(h)(3)(F): $750,000 of acquisition debt ($375,000 MFS), and no home equity debt. California does not conform. It keeps the pre-TCJA limits: $1,000,000 of home acquisition debt plus $100,000 of home equity debt ($500,000 / $50,000 MFS). Under 2017 Pub. 936, acquisition debt over $1,000,000 can count as home equity debt up to that limit.

So any CA itemizer with mortgage debt above $750,000 is under-deducted. Above $1,100,000 the California share of interest is 1,100,000 / balance, against 750,000 / balance federally.

Reproduction (main, 2.42.0)

Synthetic case: 2025, single, CA, $500,000 wages, $60,000 of mortgage interest, one loan originated in 2020, nothing else itemized.

Balance Federal deductible CA itemized (PolicyEngine) CA itemized (law)
$600,000 60,000 60,000 60,000
$900,000 50,000 50,000 60,000
$1,500,000 30,000 30,000 43,980 (0.733 × 60,000)

Sources

  • R&TC 17225(b), added by SB 711 (2025), continues nonconformity to IRC 163(h)(3)(F). See the Senate Revenue & Taxation conformity chart, PDF p. 14. Before 2025, California's IRC conformity date (R&TC 17024.5) predated the TCJA.
  • 2025 Schedule CA (540) instructions, Part II line 8: "Federal law limited the mortgage interest deduction acquisition debt maximum from $1,000,000 ($500,000 for married filing separately) to $750,000 ($375,000 for married filing separately). California law does not conform. … Federal law suspended the deduction on up to $100,000 ($50,000 for married filing separately) for interest on home equity indebtedness … California law does not conform."
  • 2017 IRS Publication 936, PDF pp. 9–11: "Debt over this limit may qualify as home equity debt", and the Table 1 worksheet.

Proposed fix

The same approach as the Hawaii change in #9950:

  • Add CA home_acquisition_debt_limit and home_equity_debt_limit parameters.
  • Add a ca_mortgage_interest_deduction variable that runs 2017 Pub. 936 Table 1 on the existing balance and origination-year inputs. Grandfathered pre-October-14-1987 debt stays unlimited, as in the federal helper.
  • Use it in ca_itemized_deductions_pre_limitation in place of the federal deductible_mortgage_interest.

Not modelled: the fair-market-value cap on home equity debt (no FMV input), and home equity debt not used to buy or improve the home (no separate input). I have a branch with YAML tests ready, and will open the PR if this approach works for you.

Activity

Sign up for free to join this conversation on GitHub. Already have an account? Sign in to comment

Metadata

Metadata

Assignees

No one assigned

    Labels

    No labels
    No labels

    Type

    No type

    Projects

    No projects

      Milestone

      No milestone

      Relationships

      None yet

      Development

      No branches or pull requests

      Issue actions