This timely year-end conversation brought together Cresset’s tax team and RSM’s national specialists to discuss the One Big Beautiful Bill Act (OBBA) and outline planning considerations for families, founders, and investors as 2025 comes to a close and new rules begin to take effect in 2026.
Key Themes
OBBA Landscape and Timing Considerations
OBBA includes a wide range of provisions with varying effective dates, combining tax cuts and revenue raisers. As year-end deadlines converge, proactive modeling may help families evaluate differences between taking action in 2025 and waiting until 2026.
SALT Planning and Entity-Level Strategies
The SALT cap increased to $40,000 for certain taxpayers, though income-based phaseouts may limit its impact for many high earners. For eligible business owners, the pass-through entity tax (PTET) election continues to be a strategy to evaluate, particularly where entity-level deductions may result in different tax outcomes depending on individual circumstances and state rules.
Charitable Giving Under New Limitations
Beginning in 2026, charitable deductions may be reduced by a new floor and an overall itemized deduction limitation, potentially affecting the tax treatment of charitable giving. For philanthropic families, accelerating certain gifts into 2025 and coordinating with donor-advised funds may help address these changes, while qualified charitable distributions from IRAs remain a planning option under current rules and are not subject to the new constraints.
Estate, Gift, and Multigenerational Planning in a “Permanent” Era
OBBA increases the estate and gift exemption to $15 million per person in 2026, though future legislative changes remain possible. The discussion emphasized building flexible estate plans, confirming available exemption amounts based on prior gifts, weighing lifetime gifting against step-up considerations, and incorporating generation-skipping strategies where aligned with family goals.
Expanded Planning Considerations for QSBS and Opportunity Zones
OBBA introduces changes affecting Qualified Small Business Stock (QSBS) planning, including higher exclusion thresholds, partial exclusions at shorter holding periods, and broader eligibility based on company asset limits, while underscoring the importance of documentation and avoiding disqualifying transfers. The bill also includes updates to Qualified Opportunity Zones through ongoing designations and additional rural incentives, alongside increased compliance and reporting requirements that may influence implementation decisions.





