Using Excess GST Tax Exemption Before It’s Lost
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. Under the OBBBA, the federal estate, lifetime gift and generation-skipping transfer (GST) tax exemption amounts increased to $15 million per individual, indexed for inflation. For many clients, this level of exemption eliminates the need for additional complex transfer tax planning. Their plans are already in place, or they can simply make lifetime gifts up to the available exemption amount.
However, a recurring issue appears when reviewing estate plans and historical gift tax filings: a disproportionate amount of unused GST tax exemption relative to the remaining lifetime gift tax exemption. This imbalance most commonly arises from planning that benefits non-ski…
