ARTICLE · 18 JULY 2025

One Big Beautiful Bill Act Enacts Changes For Estate Planning

Davis Polk & Wardwell

Explore more from Davis Polk & Wardwell

On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the "Act"). Below, we discuss key changes related to gift, estate and generation skipping transfer tax exemptions...

United StatesTax

Jillian E. Merns

Brian G. Sieben

Lucy McKinstry Taylor

Rachel Weissmann

Kate (Catherine) Ford

Pesach Herbstman

The One Big Beautiful Bill Act was signed into law on July 4, 2025, enacting significant tax law changes. This client update describes key estate planning-related provisions and highlights important considerations for estate planning clients.

On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (the "Act"). Below, we discuss key changes related to gift, estate and generation skipping transfer tax exemptions; the Qualified Small Business Stock capital gain exclusion; charitable giving; and 529 plan accounts. In an earlier client update, we discussed a variety of provisions affecting businesses and individual taxpayers, some of which may be of significant interest to estate-planning clients.1

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

Related Articles

Asia Tax Bulletin - Autumn 2026

Preparing For And Responding To IRS Penalty Notices For Employer Health Coverage Requirements

United StatesTax

Holland & Knight

The End Of The QOF Deferral Period Is Quickly Approaching. What Must I Know Before Year-end?

United StatesTax

McDermott Will & Schulte

Pied-à-Terre Tax Exemptions: Preparing For January 2027 DOF Filing

United StatesTax

Holland & Knight

IRS Issues Temporary Regulations For Federal Scholarship Tax Credit

United StatesTax

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

Comparative Guide

Tax

Comparative Guide

Tax Disputes

See more popular content from

Tax

GENIUS Act Crypto Tax Guide 2025-2026: What US Investors, Businesses, And Taxpayers Need To Know About The New Stablecoin Law, Form 1099-DA, And Digital Asset Regulation

The United States cryptocurrency regulatory landscape has undergone its most dramatic transformation in history. The signing of the GENIUS Act into law on July 18, 2025 — the first comprehensive federal crypto statute ever enacted — marks a before-and-after moment for American digital asset law.

United StatesTax

Rotfleisch & Samulovitch P.C.

California's Proposed Billionaire Tax: What You Need To Know

California's Proposition 40 would impose a one-time excise tax of up to 5 percent on billionaires' worldwide net worth, measured as of December 31, 2026, but based on residency as of January 1, 2026. The measure faces significant legal challenges and could be nullified by competing ballot initiatives that have also qualified for the November 2026 ballot.

United StatesTax

Holland & Knight

Increased Federal Estate And Gift Tax Exemption Made Permanent – Planning Considerations For High Net-Worth Individuals

Recent federal legislation has permanently extended the historically high unified exemption amount for federal estate and gift tax purposes. The current exemption of $13.99 million per individual remains in place through December 31, 2025...

United StatesTax

Stites & Harbison PLLC

Washington’s Millionaires’ Tax Heads To November Ballot

Washington voters will decide the future of the state’s new 9.9% tax on annual taxable income above $1 million after a repeal initiative qualified for the November ballot.

United StatesTax

Tax Strategies: Selling Your S Corporation Business

Selling an S corporation involves complex tax and legal considerations that can significantly impact after-tax proceeds. This comprehensive analysis examines stock sales versus asset sales, IRC Section 338(h)(10) elections, F reorganizations, and other transaction structures, revealing how different approaches affect both sellers and buyers through detailed tax modeling and strategic planning insights.

United StatesTax

New Prize Tax Rules Raise The 1099 Threshold For Sweepstakes And Contests

Among the many changes included in the One Big Beautiful Bill Act (OBBBA) is one relevant to brands and agencies running sweepstakes, contests, and other consumer promotions.

United StatesTax

Global Advertising Lawyers Alliance (GALA)

Form 5472 And Foreign-Owned U.S. Entities: The New Chief Counsel Guidance

Foreign owners of single-member U.S. limited liability companies often assume their entities are completely disregarded for tax purposes, but since 2017, these structures face significant reporting obligations...

United StatesTax

The First Round Of Saver’s Match Guidance Is Here

The Treasury Department and IRS have released Notice 2026-48, providing the first comprehensive guidance on SECURE 2.0's new Saver's Match program. This federal matching contribution for low- and moderate-income retirement savers introduces complex implementation challenges, including how to route taxpayer matches directly to retirement plans and IRAs. The Notice addresses eligibility requirements, income limits, contribution types, and delivery mechanisms while requesting public comments on operational app

United StatesTax

Groom Law Group, Chartered

A 5% Wealth Tax? Preparing Clients For California's Billionaire Tax Act

California's proposed Billionaire Tax Act would impose a onetime 5% excise tax on individuals and trusts with assets exceeding $1 billion, creating unprecedented challenges for estate planners. The retroactive application and anti-abuse provisions raise critical questions about the treatment of grantor trusts, non-grantor trusts, and beneficiary interests that deviate significantly from established federal wealth transfer tax principles.

United StatesTax

The Fine Print Of 529 Plans: What New York Doesn't Cover

Section 529 plans provide a tax-advantaged way to save for education expenses, but account holders should be mindful of important differences...

United StatesTax