Current Developments Overview of Selected Provisions in, Background Behind, and Planning Considerations Under Reconciliation Legislation

The 2025 reconciliation act (referred to as the One Big Beautiful Bill Act (OBBBA), though that is not the official name of the Act) generally extends and enhances provisions in the 2017 Tax Cuts and Jobs Act permanently (until changed by a future Congress). The estate, gift, and GST “exemption” is increased (also permanently) to $15 million in 2026 (with future inflation indexing). Selected provisions of the Act, “behind the scenes” issues and negotiations underlying the Act, and planning considerations (including an increased emphasis on nongrantor trust planning and basis adjustment planning) are summarized.