One Big Beautiful Bill Act: STEP Panel on the $15 Million Estate Tax Exemption and International Tax Changes
Updated: Oct 28
STEP’s panel reviewed how the new U.S. legislation will affect high-net-worth clients with international ties and practical planning steps advisers should consider. The session explains which provisions change timing or substance of estate, gift and international tax planning and highlights immediate opportunities and risks for cross-border estates.
Key takeaways
The One Big Beautiful Bill Act (OBBB) was signed into law on 4 July 2025; it makes multiple substantive changes to the Internal Revenue Code that affect both domestic and cross-border planning.
The federal estate, gift and generation-skipping transfer exemption is now permanent and has been increased to $15 million (single) / $30 million (married) for tax year 2026 (indexed for inflation). That change materially affects transfer timing and the use of dynasty trusts.
Section 529 rules expand allowable distributions (K–12 and other items); advisers should reassess education-savings strategies and contribution timing in light of the new limits.
State-level workarounds such as PTETs and prior IRS guidance may need re-evaluation because the federal treatment of SALT and related guidance could shift under OBBB.
Practical actions discussed: review existing wills and cross-border choice-of-law steps, consider separate instruments or trusts for U.S. real estate, and accelerate or redesign lifetime transfers where appropriate to capture current rules.
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