The $15 Million Exemption Is Permanent: Why Pre-Sunset Bypass Trusts and SLATs May Now Work Against Your Clients
OBBBA made the estate, gift, and GST exemption permanent at $15 million per person, ending the multiyear sunset rush that drove private-client planning since 2022. The cliff is gone, but the structures built to beat it remain: formula-funded credit shelter trusts that mechanically over-fund the bypass and forfeit a second basis step-up, aggressive SLATs and IDGTs that now carry grantor-trust income-tax drag for no transfer-tax purpose, and disclaimer plans whose default has quietly become outright passage. The right response is not to re-announce the number but to re-read the documents against it.
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