Overview
- The One Big Beautiful Bill raises the federal estate and gift tax exemption to $15 million per person ($30 million for couples) and indexes it to inflation, reshaping wealth‑transfer strategies.
- Estate planners recommend using the larger exemptions now through lifetime gifts, with appreciating assets like closely held businesses and real estate highlighted as candidates; some warn valuation discounts could face future limits.
- Dynasty trust planning gains prominence as experts advise coordinating estate and GST exemptions, with some suggesting shifts to irrevocable non‑grantor trusts to capture the higher $40,000 SALT deduction and the now‑permanent QBI deduction at the trust level.
- Charitable giving faces new constraints, including a 0.5% AGI haircut and a cap that limits the tax benefit to an assumed 35% rate, leading advisers to recommend accelerating major donations before December 31, 2025.
- Permanent business provisions such as 100% bonus depreciation (full expensing) and preserved pass‑through benefits alter cash‑flow and investment decisions, while separate state estate taxes—especially in New York, Massachusetts, and Oregon—still warrant document reviews.