Estate planning at the $10 million and above level is a fundamentally different conversation than it is for most families. The assets are more complex. The tax exposure is greater. And the tools available are more sophisticated and the cost of getting it wrong is measured in millions, not thousands.
As many of you already know, the landscape shifted in 2026. The One Big Beautiful Bill Act permanently raised the federal estate and gift tax exemption to $15 million per individual ($30 million for married couples using portability) effective January 1, 2026, with annual inflation adjustments going forward.
For families in the $10M to $15M range, this change removes federal estate tax exposure that existed just a year ago. But for families above the exemption, or those with complex asset structures, the planning work is far from done.
The Federal Exemption Is Only Part of the Picture
Even with a $15M exemption, the federal estate tax rate above that threshold remains 40%. And the federal exemption is only one layer. Twelve states plus Washington, D.C. impose their own estate or inheritance taxes, often with exemption thresholds lower than the federal level.
Connecticut, Massachusetts, Oregon, and Washington all have state estate taxes that can create meaningful exposure for estates that fall well under the federal limit. For families with real estate, business interests, or accounts in multiple states, multi-state exposure requires deliberate attention.
Portability Is Valuable, But Not Automatic
For married couples, portability allows a surviving spouse to inherit the deceased spouse’s unused exemption, shielding up to $30 million from federal estate tax as a couple. But portability is not automatic. The executor must file IRS Form 706 and make the election within nine months of death. Failing to file, even for estates that owe no tax, can forfeit the unused exemption entirely, leaving the surviving spouse with a significantly smaller shield. At this wealth level, that oversight could cost millions.
Trust Strategies Remain Essential
A higher exemption doesn’t eliminate the value of trust-based planning. It simply changes the formula. For families above the $15M threshold, irrevocable trust structures such as SLATs, IDGTs, and dynasty trusts continue to serve two purposes: removing future appreciation from the taxable estate and providing structured, protected wealth transfer to the next generation.
Equally important is the generation-skipping transfer tax exemption. This also sits at $15M per person in 2026, matching the estate tax exemption. For families looking to transfer wealth directly to grandchildren or into dynasty trusts that span multiple generations, the current environment is unusually favorable. Assets transferred now remove not just current value but all future appreciation from the taxable estate.
Liquidity Planning Is Often Overlooked
High-net-worth estates frequently hold a large amount of illiquid assets. Like business interests, real estate, private equity, or concentrated stock positions. If estate taxes are owed, the IRS requires payment in cash within nine months of death. Families without adequate liquid assets to cover that bill may be forced to sell assets under unfavorable conditions to meet the obligation.
Life insurance held in an Irrevocable Life Insurance Trust (ILIT) is one of the most efficient ways to pre-fund estate tax liquidity. The proceeds pass outside the taxable estate. And they are available immediately when needed, providing a clean, liquid solution to what can otherwise become a forced and costly asset sale.
The Conversation Worth Having Now
The 2026 exemption increase is a meaningful development, but it’s not a reason to defer planning. Tax laws change. Exemptions that are permanent today can be modified by future Congresses. The planning decisions made now, around trust structures, gifting, portability, and liquidity, will shape the financial legacy left behind for decades.
A qualified financial professional at Barnum Financial Group, working alongside your estate attorney and tax counsel, can help you evaluate where your estate stands under current law and identify the strategies most appropriate for your specific assets, family structure, and long-term goals.
Neither MML Investors Services nor any of its subsidiaries, employees or agents are authorized to give legal or tax advice. Consult your own personal attorney, legal or tax counsel for advice on specific legal and tax matters.
