The wealthiest among us—in economist talk, ultra-high-net-worth individuals, or UHNWIs—have long hated the 40 percent estate tax. The 2017 Tax Cuts and Jobs Act (TCJA) offered some relief by increasing every taxpayer’s ability to make tax-free gifts before 2026, temporarily raising the lifetime exemption (the amount that goes untaxed) from $5 million to more than $13 million for individuals and double that amount for couples. The key word here is ‘temporarily.’ The TCJA lowered tax rates, reduced the number of income tax brackets, reduced and in some cases eliminated the alternative minimum tax and increased the standard deduction in perpetuity, but some changes enacted by the law will expire at the end of 2025.
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The increase in the lifetime exemption amount is among the sunsetting elements, and some estate tax planners are advising clients to take advantage of the higher amounts before that exemption drops to 2017 levels, adjusted for inflation—approximately $7 million in 2026. “This has been the number one estate planning conversation with ultra-high........