Under IRC §1014(b)(6) both halves of community property reset to fair market value at the first death, not just the decedent's half. On a rental that went from a $100,000 adjusted basis to $1,300,000, holding it in joint tenancy instead costs the surviving spouse $147,800.
A portability election belongs on a Form 706 due nine months after death, but Rev. Proc. 2022-32 gives most estates that owed no tax five years from the date of death to file it anyway. On a 2022 death, that late election is still worth up to $12,060,000 of exclusion.
A trust hits the top 37% bracket at just $16,000 of income in 2026, plus a 3.8% surtax. The 65-day rule lets you move that income onto a beneficiary's return at a lower rate, if you distribute in time and check the box on Form 1041.
Gift splitting lets a married couple treat one spouse's gift as made half by each, giving one recipient two $19,000 annual exclusions in 2026. The election covers every third-party gift that year and often requires two separate Forms 709.
The One Big Beautiful Bill Act set the federal estate and gift tax exemption at $15 million per person for 2026 and removed the sunset that was going to cut it roughly in half. For most families that means no federal estate tax, but the planning that mattered before still matters.
Elon Musk has pledged more than 236 million Tesla shares to banks. Carl Icahn carried a $1.2 billion loan and paid $0 federal income tax in two separate years. This is the buy, borrow, die tax strategy, how it works, the IRC §1014 step-up that makes it permanent, and what the 2026 law and Moore v. United States changed.
Weeks before Facebook went public, co-founder Eduardo Saverin gave up his US passport and moved his roughly 4% stake to Singapore. The move drew a Senate bill named after him and saved a reported nine figures in future US tax. Here is how the exit tax for renouncing US citizenship works under IRC §877A, who counts as a covered expatriate at the 2026 numbers, and why the date you leave decides the bill.
Audrey Walton put $200 million of Walmart stock into two GRATs and reported a $0 taxable gift. The Tax Court blessed it, and casino magnate Sheldon Adelson later moved $7.9 billion to his heirs the same way. Here is how the grantor retained annuity trust estate tax strategy works, the Walton case that made it bulletproof, and what a zeroed-out GRAT saves at the 2026 numbers.
Donald Trump claimed a $21.1 million charitable deduction for a conservation easement on land he kept. The strategy is legal, but the fight is always about the appraised number. Here is how the conservation easement tax deduction works, what the §170(h)(7) crackdown changed, and how the 2026 charitable rules shift the math.
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Wealth-transfer planning
Moving the assets before the tax follows.
The estate exemption, the step-up in basis, and a well-timed trust decide how much of an estate reaches the next generation instead of the IRS. These moves reward planning made years ahead, not a signature in the final month. We model the transfer, structure the trust, and file the returns, so the wealth passes on the terms you set.