July Fourth Changed Estate Planning Forever

The frantic rush to beat 2026 just ended.
H.R. 1, signed July Fourth, eliminates the uncertainty that has dominated family office strategies for nearly a decade. The permanent exemption creates a $15 million federal estate and gift tax threshold per individual. For married couples, that means $30 million with no sunset provision.
I've watched complex families scramble since the Tax Cuts and Jobs Act created temporary provisions. Every strategy carried expiration anxiety. Every plan included contingency scenarios.
That planning environment just fundamentally shifted.
The Permanence Factor
Previous estate planning operated under constant threat of legislative reversal. Families rushed to implement strategies before arbitrary deadlines. The new framework removes that pressure entirely.
This creates space for thoughtful, long-term wealth transfer strategies. Families can now build multi-generational structures without racing against political calendars.
The legislation also addresses immediate pain points. SALT deduction caps increase to $40,000 through 2029, providing relief for families in high-tax states. While temporary, this provision costs an estimated $142 billion and signals continued focus on tax burden reduction.
QSBS Expansion Creates New Opportunities
The enhanced Qualified Small Business Stock provisions deserve particular attention from family offices. Asset caps rise from $50 million to $75 million. Individual benefit caps increase from $10 million to $15 million.
The tiered exclusion structure creates powerful incentives: 50% capital gains exclusion for three-year holds, 75% for four years, and complete exclusion after five years.
For families with entrepreneurial investments, this transforms the risk-reward calculation. A $15 million investment could ultimately shield $150 million from federal capital gains taxes.
Strategic Implications for Complex Families
The permanence changes how we approach multi-generational planning. Time becomes the primary wealth transfer tool rather than legislative timing.
Grantor trust strategies gain new appeal with extended planning horizons. Income-shifting techniques can operate without expiration concerns. Charitable planning structures benefit from stable exemption amounts.
However, permanence doesn't eliminate the need for regular plan reviews. Asset appreciation and family dynamics still require ongoing attention.
The Congressional Budget Office projects H.R. 1 will increase real GDP by 0.5% over the next decade, with peak effects reaching 0.9% in 2026. This economic environment supports asset appreciation assumptions underlying many wealth transfer strategies.
Implementation Considerations
Existing estate plans require immediate evaluation against the new permanent thresholds. Many strategies implemented under time pressure may benefit from restructuring.
Trust document reviews should examine powers of substitution and administrative provisions. Some temporary structures may warrant conversion to permanent arrangements.
The enhanced exemptions create opportunities for families who previously couldn't justify complex planning costs. Mid-tier wealth families can now access strategies previously reserved for ultra-high net worth situations.
Independence in reporting becomes crucial as families navigate these expanded opportunities. The permanent nature of H.R. 1 demands strategic thinking unclouded by product sales or advisory conflicts.
For the first time in years, families can plan without watching the political calendar.
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