Estate tax permanent $15M exemption post-OBBBA + proposed cuts + QSBS decoupling + dynasty bill
Key Questions
What is the new estate tax exemption under OBBBA?
OBBBA locks in a permanent $15M individual and $30M couple exemption. Step-up in basis remains unchanged.
How can PPLI help ultra-high-net-worth families?
PPLI offers tax-deferred growth and tax-free transfers for UHNW estates. It is emerging as a key planning tool alongside Roth conversions.
What is the IRMAA trap for business sellers?
A two-year lookback on income can trigger up to $13,872 in additional Medicare surcharges annually. Proper timing of sales is critical.
Are Trump Account contributions eligible for gift tax exclusion?
The IRS has clarified that Trump Account contributions qualify as present-interest gifts. This allows use of the annual gift tax exclusion.
What estate planning gaps exist among wealthy families?
A BofA study shows half of wealthy families lack formal estate plans despite longevity awareness. Demand for planning has shifted from optional to expected.
How does the California billionaire tax affect relocation?
The proposed tax adds urgency for HNWI relocation planning to states like Nevada. It targets net worth above $1B at a 5% rate.
What after-tax strategies exist for IPO exits?
Strategies include exclusion, deferral, offsetting, and hedging approaches. These help minimize taxes for early investors and founders.
What resources address blended family estate planning?
New guides cover revocable versus irrevocable trusts and specific steps for blended families. Divorce real estate tax planning is also addressed.
OBBBA locks $15M individual/$30M couple exemption; step-up in basis unchanged. IRS clarifies Trump Account contributions qualify for annual gift tax exclusion as present-interest gifts. PPLI (Private Placement Life Insurance) emerges as tax-deferred growth/tax-free transfer tool for UHNW families. IRMAA trap for business sellers (two-year lookback can add $13,872/yr in surcharges). Roth conversion bracket-fill logic. After-tax IPO strategies (exclusion, deferral, offsetting, hedging). BofA study: wealthy families aware of longevity risks but half lack estate plans. Estate planning demand shifting from optional to expected. California billionaire tax proposal adds urgency for HNWI relocation planning. New resources: revocable vs irrevocable trust breakdown, blended family estate planning guide, divorce real estate tax planning.