Estate tax permanent $15M exemption post-OBBBA + proposed cuts + QSBS decoupling + dynasty bill
Key Questions
What changes did the OBBBA make to estate and gift tax exemptions?
The OBBBA permanently set the federal estate and gift tax exemption at $15 million per person or $30 million per couple starting in 2026. It also locked in TCJA and SALT provisions with new charitable floors.
How can Nevada situs provide tax savings in estate planning?
Nevada situs for asset protection can yield up to $13 million in savings on a $100 million exit. This leverages favorable state rules for high-net-worth individuals.
What planning strategies are recommended for §1250 recapture?
§1250 recapture can be addressed through 1031 exchanges, QOZ investments, or estate planning techniques. Pre-sale planning is advised 3-5 years ahead.
How do trust taxation rates compare to individual rates?
Trust taxation rates are materially higher than individual rates, creating a key hidden cost in multi-generational planning. This affects long-term wealth transfer strategies.
What is the new permanent estate tax exemption amount?
The 2026 lifetime gift and estate tax exemption is $15 million per individual or $30 million per couple. It was made permanent under recent legislation.
Why is pre-exit inheritance tax planning important for business owners?
Selling a business can trigger large inheritance tax bills without advance planning. Strategies should begin 3-5 years before an exit.
What extensions or changes apply to Qualified Opportunity Zones under OBBBA?
OBBBA includes QOZ extensions alongside new charitable requirements. These support continued tax deferral options for real estate and other assets.
How does QSBS interact with the new exemption rules?
QSBS can help exclude up to $15 million in capital gains for tech founders and employees. It may decouple from certain estate tax provisions under the new framework.
OBBBA locks TCJA/SALT $40k permanently with new charitable floors, QOZ extensions; new $15M individual/$30M couple exemption; NV situs for asset protection yields $13M savings on $100M exit. §1250 recapture planning via 1031/QOZ/estates emphasized. Trust taxation rates materially higher than individuals—key hidden cost for multi-gen planning; pre-sale inheritance tax planning 3-5 years ahead.