For three years our trust and estate practice modeled an estate exemption sunset to roughly $6.8 million per person on January 1, 2026. We funded SLATs. We accelerated GRATs. We had hard conversations with second-marriage couples about portability elections. And then on July 4, 2025, Congress, in §70106 of the One Big Beautiful Bill Act, amended IRC §2010(c)(3) to set the basic exclusion amount at $15 million per person beginning January 1, 2026, indexed for inflation starting in 2027, with no sunset. ¹
For wealthy families, this is the most material estate tax change since 2012. For our practice, it is a moment of reckoning: plans built for a $6.8 million cliff need to be re-examined.
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