The One Big Beautiful Bill Act changed everything. Here's what it means for you.
Estate Planning in 2026: The $15 Million Window
The estate tax exemption just went up. That's the good news. The opportunity is using it strategically before your estate outgrows it. Here's the complete playbook.
What Just Changed
The One Big Beautiful Bill Act (Public Law 119-21)
Signed July 4, 2025. These changes are permanent, indexed to inflation, with no sunset.
| Provision | Before (2025) | After (2026+) |
|---|
| Estate/Gift Exemption (per person) | $13,990,000 | $15,000,000 |
| Estate/Gift Exemption (married couple, using both exclusions or portability) | $27,980,000 | $30,000,000 |
| Sunset provision | Was set to revert to ~$7M | No sunset. Permanent. |
| Inflation indexing | Yes | Yes (begins 2027, base year 2025) |
| Estate tax rate above exemption | 40% | 40% (unchanged) |
| Gift tax annual exclusion | $19,000 | $19,000 (unchanged) |
The feared sunset did NOT happen. The exemption INCREASED. But 40% still applies to everything above $15M ($30M for a couple that uses both). If your estate is growing at $2M/year, you'll exceed $15M in 3-5 years.
Four Strategies to Use the $15M Window
1. Irrevocable Life Insurance Trust (ILIT)
Move $5M+ outside your taxable estate permanently.
An ILIT is a trust that owns your life insurance policy. Because the trust owns it (not you), the death benefit is not part of your taxable estate. If the trust bought the policy, or you moved it in more than 3 years before death, the $5 million reaches your family free of income and estate tax. Even if your estate exceeds the $15M exemption, the ILIT portion is protected.
Impact
$5,000,000+ transferred tax-free (IRS requirements apply)
Outside your estate if the trust bought the policy, or you moved it in more than 3 years before death
2. Strategic Annual Gifting
Move about $3M out of your estate over 20 years with zero gift tax.
You and your spouse can each give $19,000 a year to anyone in 2026 ($38,000 together). If one spouse writes the whole check, you file a gift tax return to split it; no tax is due. Over 20 years to 4 people (children, grandchildren), that's about $3 million out of your estate with no gift tax and none of your $15 million used. The money is out. It grows in their hands, not yours. And it moved out of your estate with no gift tax.
Impact
$3,040,000 transferred tax-free (within IRS limits)
$38K/year x 4 people x 20 years, zero gift tax
3. Dynasty Trust
Protect wealth for your grandchildren's grandchildren.
A dynasty trust is designed to last for multiple generations. You transfer assets into the trust using your lifetime exemption. The trust grows, distributes income to beneficiaries, and passes wealth across generations without estate or GST tax at each generation, if you allocate GST exemption to it. Your children don't just inherit once. The trust keeps growing and protecting for generations.
Impact
Multi-generational tax-free wealth (IRS requirements apply)
One-time use of your $15M gift and GST exemptions helps protect wealth across generations
4. The Digital eState Plan
A digital estate plan keeps the trust online. Changes to a trust are legal changes, so talk with an estate-planning attorney first.
When was the last time you looked at your estate plan?
If it's been more than a year, your trust may not reflect your current assets, beneficiaries, or the new $15M exemption. That isn't the outcome you want.
Every move in your plan names the section of the Internal Revenue Code behind it and the form it lands on. Your CPA can file it, and you can check it.
The system behind every plan: seven areas of the tax code, checked against your facts, in the same order, every time.
