Overview
- From 2026, the estate, gift and GST exemptions rise to $15 million per person with indexing and no scheduled sunset, reshaping transfer-tax priorities for many families.
- For 2025–2029, the SALT deduction cap increases to $40,000 with a phase-out above $500,000 of income, prompting coordination with pass-through entity elections and multistate planning.
- Qualified Small Business Stock rules expand in 2026, including a $15 million per‑issuer exclusion cap (indexed), a $75 million asset threshold and a shorter holding period enabling tiered exclusion strategies.
- FinCEN has suspended Corporate Transparency Act BOI enforcement for domestic reporting companies as it re-examines rules, while foreign reporting continues and timing questions remain for prior filings.
- International updates under OBBBA include restoration of the rule limiting downward attribution, renaming and rate changes that lift effective NCTI and FDDEI taxation to about 14%, a permanent 10.5% BEAT rate from 2026, broader pro rata inclusion for any-day CFC ownership and a new 1% excise tax on certain outbound remittances with provider withholding duties.