Estate Planning Impact of the “One Big Beautiful Bill Act”
On July 3, 2025, Congress passed a major taxation and spending bill commonly known as the “One Big Beautiful Bill Act“. The following provisions of the Act may be of interest to estate planning clients:
1. Increased Estate and Gift Tax Exemption. The federal estate, gift, and generation-skipping tax exemption amounts permanently increase to $15 million per person effective January 1, 2026, and will be adjusted for inflation in future years. The current exemption is $13.99 million per person.
2. Higher SALT Deduction Cap. The individual state and local tax deduction limitation (SALT limitation) increases to $40,000 and is indexed for inflation through tax year 2029, after which the cap reverts to $10,000. The cap is phased down for taxpayers with modified adjusted gross incomes over $500,000. For tax years after 2029, the cap returns to $10,000.
3. Expanded QSBS (Qualified Small Business Stock) Benefits. The Act enhances the tax exclusion under Section 1202 for QSBS as follows:
- Provides a tiered gain exclusion for QSBS, permitting a 50% exclusion for shares held more than three years, a 75% exclusion for shares held more than four years, and a 100% exclusion for shares held more than five years.
- Increases the per-issuer dollar cap from $10 million to $15 million (indexed to inflation beginning in 2027).
- Raises the corporate-level gross assets ceiling from $50 million to $75 million (indexed to inflation beginning in 2027).
If you have questions about how these changes may affect your estate plan or business holdings, please do not hesitate to contact an attorney at Sims & Campbell to discuss any questions you may have regarding the “One Big Beautiful Bill Act”.