A Historic Tax Reform — With an Expiration Date
Signed into law on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) represents one of the most comprehensive federal tax reforms in decades. While legislatively “permanent,” history shows us that no tax law in Washington, D.C. is truly immune to change. The next Congress could undo or modify these provisions.
What OBBBA truly provides is a three-year window. During this time, families, business owners, and high-net-worth individuals should assemble a trusted planning team—including an attorney, accountant, investment advisor, and insurance specialist—to implement strategies designed to minimize looming income and estate tax burdens.
At The Smith Legacy Group, we help clients take advantage of this critical window of opportunity.
Relevant Planning Strategies Under OBBBA
Annual Exclusion Gifting
- The annual exclusion gift limit is $19,000 per donee per year.
- While small gifts may seem modest, over time they compound into significant estate tax savings. Starting early is key.
Lifetime Exemption Gifting
- Beginning in 2026, the lifetime exemption increases to $15 million.
- Most large gifts should be made in trusts, which need to be carefully drafted and executed.
Irrevocable Grantor Trusts
- A proven tool to remove assets from the taxable estate.
- Can be funded through gifts, loans, or other wealth-shifting strategies.
State Estate Taxes
- OBBBA does not provide relief for residents in states with estate or inheritance taxes. State-level planning remains essential.
Asset Valuation & Discounts
- Strategies that reduce the assessed value of estate assets can provide meaningful tax savings
SLATs (Spousal Lifetime Access Trusts)
- Allow taxpayers to use lifetime exemptions while retaining indirect access to assets.
Life Insurance as an Asset Class
- Provides uncorrelated death benefits, tax-free accumulation, and liquidity for estate planning.
Buy/Sell Planning After Connelly
- A timely opportunity to review existing business buy/sell agreements to ensure compliance and tax efficiency.
Key Sales & Planning Opportunities
- Foreign Nationals: U.S. residents face U.S.-level estate taxes; non-residents have very low exemptions on certain U.S. assets.
- Life Settlements: Clients with non-taxable estates may benefit from selling existing policies.
- Intergenerational Split Dollar: Effective for wealth transfer when Gen 1 has maxed exemptions and Gen 2 has liquidity or tax exposure.
- Divorce Planning: Special considerations when dividing assets with only one $15M exemption.
- Executive Benefits Planning: Retain and reward key management with tax-efficient solutions.
- Premium Financing: Still viable in today’s rate environment for funding large policies.
- Leveraging Qualified Assets: Using after-tax distributions or RMDs to fund life insurance, creating tax-free benefits for heirs.
The Three-Year Window: Act Now
OBBBA is reshaping the tax landscape, but opportunities are time-sensitive. Strategies like gifting, trust planning, and life insurance optimization require careful design and execution—and cannot be implemented overnight.
At The Smith Legacy Group, we work hand-in-hand with your legal, tax, and financial advisors to help you:
- Protect your wealth from unnecessary taxation.
- Transfer assets efficiently to future generations.
- Maximize the unique opportunities created under OBBBA.
Final Thoughts
The One Big Beautiful Bill Act is not just a tax reform—it’s a call to action. With only a three-year planning window, now is the time to explore sophisticated estate and tax strategies that align with your family’s long-term goals.
✨ At The Smith Legacy Group, we bring clarity, expertise, and trusted guidance to help you make the most of this unprecedented opportunity.
