The $15 Million Question: What the Permanent Exemption Changed and What It Didn’t
For most of the last decade, high-net-worth estate planning ran on a clock. Advisors and attorneys urged families to act before a looming deadline — the scheduled rollback of the federal estate tax exemption — and “use it or lose it” became the defining phrase of the era.
That clock has stopped. The One Big Beautiful Bill Act, signed in July 2025, permanently set the federal estate and gift tax exemption at $15 million per individual — $30 million for married couples — beginning in 2026, indexed for inflation, with no sunset. The deadline that shaped years of planning is simply gone.
It’s tempting to read that as “I’m under the threshold, so I’m finished.” That conclusion is where expensive mistakes begin.
A permanent exemption doesn’t end estate planning — it changes what matters. The urgency that drove aggressive lifetime gifting has eased, and in its place the real priorities come into focus: state-level estate taxes, which apply at far lower thresholds than the federal exemption and reach families who own property in multiple states; income-tax efficiency and how assets receive a step-up in basis at death; liquidity, so heirs aren’t forced to sell a business or property to cover costs; and flexibility, so a plan can adapt the next time the law shifts — because in tax law, “permanent” means “until Congress decides otherwise.”
And for families above $15 million, exposure hasn’t gone anywhere. The planning conversation has simply moved from beating a deadline to building a durable, long-term strategy.
Here’s the quieter risk: many existing plans were drafted for a different law. Trust formulas that reference the exemption amount can now distribute assets in ways the family never intended, precisely because the number jumped so far. A plan that was perfectly calibrated three years ago may quietly do something else today.
The exemption is settled. Whether your plan still reflects your intentions is the question worth asking — and it’s best answered by your attorney and your financial advisor reading the same plan side by side. Coordinating that review, and keeping your financial strategy aligned with your legal documents, is exactly the work I do alongside your estate counsel.



