How much can I gift tax-free in 2026?

You can give $19,000 per recipient in 2026 — to as many people as you like — with no gift tax and no return to file. A married couple using gift-splitting can give $38,000 per recipient. Gifts above that aren’t taxed immediately; they’re reported on Form 709 and count against your $15 million lifetime exemption. Paying someone’s tuition or medical bills directly to the institution is unlimited on top of the $19,000.

What is a SLAT and how does it work?

A Spousal Lifetime Access Trust lets one spouse move assets out of the taxable estate while the other spouse can still benefit from them. The creating spouse funds an irrevocable trust for the beneficiary spouse; the assets and all future growth leave both estates, but the beneficiary spouse can receive income or principal under the trust terms. It’s irrevocable, so the gift can’t be unwound — and if both spouses create SLATs, the trusts must differ meaningfully to survive IRS scrutiny.

How does a GRAT pass wealth to heirs?

You contribute appreciating assets to the trust, keep an annuity stream for a set term, and the growth above the IRS’s assumed interest rate passes to heirs with little or no gift tax. GRATs work best for assets expected to grow fast — private company shares, concentrated stock, real estate. The main risk is dying during the trust term, which pulls the assets back into your estate; short rolling terms manage that risk.

Do I still need an ILIT if my estate is under the $15 million exemption?

Often, yes — for liquidity and state taxes. If you own a life insurance policy personally, the death benefit counts in your taxable estate, and many states tax estates at far lower thresholds than the federal $15 million. An ILIT keeps the proceeds outside the estate and gives your heirs cash to pay taxes and expenses without forcing a sale of the business or property.

Is the estate tax sunset really cancelled?

The scheduled 2026 sunset is gone — the One Big Beautiful Bill Act set the $15 million exemption permanently, with inflation adjustments starting in 2027. But “permanent” only means nothing is scheduled to expire; a future Congress can still change the law. The prudent move is to plan under today’s generous rules while reviewing the plan every few years.

Estate Planning

Estate Planning for High Net Worth Families: 2026 Guide

Estate planning for high net worth families got a reset in 2026: the One Big Beautiful Bill Act made the $15 million per-person estate tax exemption permanent, killing the sunset everyone had been bracing for. The families who keep the most wealth across generations now compete on strategy: SLATs, GRATs, ILITs, and generation-skipping trusts, plus the family governance that makes money survive its heirs.

MKD Editorial Team October 19, 2026 6 min read Figures checked 19 Oct 2026

Flat fintech illustration in deep teal and gold: a deep teal family tree with gold coin leaves, a teal house with gold windows, a teal vault door with a gold dial, gold scrolls and an upward gold bar chart on pale cream, no text. — The 2026 reset: a permanent $15 million exemption moves the game from panic to strategy.

Key takeaways

The 2026 exemption is $15 million per person ($30 million married) — permanent under the One Big Beautiful Bill Act, indexed from 2027.
The 2026 annual gift exclusion is $19,000 per recipient — unchanged from 2025.
SLATs let a couple use the exemption now while a spouse keeps access to the funds.
GRATs pass future growth on fast-appreciating assets to heirs with little or no gift tax.
ILITs keep life insurance out of the taxable estate and create liquidity for illiquid estates.

What changed in 2026: the sunset is gone

For years, wealthy families planned around a cliff: the old exemption was scheduled to sunset at the end of 2025, roughly halving it. The One Big Beautiful Bill Act erased that cliff and set the basic exclusion amount at $15 million per person, permanently — a married couple can shield $30 million (IRS IR-2025-103; Rev. Proc. 2025-32 details), inflation-indexed from 2027. Two caveats: “permanent” means nothing is scheduled to expire — Congress can still rewrite it — and many states tax estates at far lower thresholds.

The 2026 numbers to know

$15 million — federal estate and gift tax exemption per person (up from $13.99 million in 2025).
$30 million — effective exemption for married couples, via portability.
$19,000 — annual gift tax exclusion per recipient, unchanged from 2025. A couple gift-splitting can give $38,000 per person, to as many people as they like, with no return and no tax.
40% — the top federal rate on amounts above the exemption.

The $19,000 exclusion is the most underused tool in wealth transfer: a couple with three children and five grandchildren can move $304,000 a year out of their estate, tax-free. Tuition or medical bills paid directly to the provider are unlimited on top of it. Portability still matters — the surviving spouse only keeps the unused exemption if the estate files a timely return electing it.

SLATs: give it away, keep the access

A Spousal Lifetime Access Trust (SLAT) lets a married couple use the exemption now without locking the money away forever. One spouse funds an irrevocable trust for the other’s benefit at today’s valuations, removing those assets — plus all future growth — from both spouses’ taxable estates, while the beneficiary spouse can still receive income or principal under the trust’s terms.

The gift is irrevocable. If both spouses create SLATs, the trusts must differ meaningfully or the IRS can collapse them under the reciprocal-trust doctrine. This is bespoke attorney work; see what estate planning attorneys charge.

GRATs: pass the growth, keep the principal

A Grantor Retained Annuity Trust (GRAT) is built for assets expected to appreciate fast — private company stock, concentrated positions, real estate. You contribute assets, keep an annuity stream for a set term, and the growth above the IRS’s assumed rate passes to heirs with little or no gift tax. The main risk is dying during the term, which pulls assets back into your estate — hence short, rolling terms.

Flat fintech illustration in deep teal and gold: a teal shield with a gold checkmark in front of a teal vault door, gold coin stacks, a document with a gold seal, and a rising gold arrow chart on pale cream, no text. — Shield the assets, move the growth: SLATs, GRATs, and ILITs each solve a different tax problem.

ILITs: insurance that doesn’t inflate your estate

Life insurance proceeds count in your taxable estate if you own the policy. An Irrevocable Life Insurance Trust (ILIT) owns the policy instead, so the death benefit reaches beneficiaries outside the estate. ILITs are also the liquidity engine for families whose wealth sits in a business or real estate: those assets can’t pay a tax bill on a deadline, but insurance proceeds can (Insurance and Estates’ 2026 HNW guide).

The detail that makes or breaks an ILIT: Crummey notices. The annual notices qualify contributions for the $19,000 exclusion — skip them and the funding gifts lose it.

GSTT and dynasty planning: skip a generation

The generation-skipping transfer tax adds a second tax layer when wealth jumps a generation. The 2026 GSTT exemption is also $15 million per person, and allocating it to a long-term dynasty trust lets assets compound for grandchildren and beyond without fresh tax at each generation.

The part most families skip: family governance

Most family fortunes are lost not to taxes but to unprepared heirs: trustee selection (a corporate trustee brings objectivity — see our guide to trustee rules); heir education so beneficiaries understand the plan before the money arrives; yearly family meetings to keep misunderstandings from becoming lawsuits; and charitable vehicles like donor-advised funds that move wealth out of the estate.

A revocable living trust still anchors the structure — it avoids probate and keeps the plan private. See how to avoid probate and what trusts cost to set up.

Bottom line

Estate planning for high net worth families in 2026 is a long game: use the $19,000 annual exclusion every year, deploy SLATs and GRATs while the $15 million exemption is favorable, keep insurance in an ILIT, and prepare your heirs as carefully as you shelter the assets. Review every two to three years and after any big event.

Your home is probably your biggest single asset

Know what the real estate side of your estate costs to carry before you fund trusts or gift shares.

Try the mortgage calculator

Sources & further reading

IRS Newsroom — IR-2025-103: Tax Inflation Adjustments for 2026Rev. Proc. 2025-32; OBBBA amendments — irs.gov, curl 200, 19 Oct 2026.
Montgomery Purdue — 2026 Update on Federal Transfer Tax Exemption and Annual Exclusion$15M exemption (up from $13.99M); $19,000 annual exclusion unchanged — curl 200, 19 Oct 2026.
Rehberg Law Group — IRS Releases 2026 Exemption and Exclusion AmountsRev. Proc. 2025-32 summary: $15M exemptions; $19,000 annual exclusion — curl 200, 19 Oct 2026.
SmartAsset — Tax Planning for Ultra-High-Net-Worth Individuals and Families$19,000/$38,000 exclusion mechanics; $15M/$30M limits — curl 200, 19 Oct 2026.
Legacy Law Group Colorado — Estate Planning for High Net Worth FamiliesSLAT, GRAT, and ILIT mechanics — curl 200, 19 Oct 2026.
Insurance and Estates — High Net Worth Estate Planning With Life Insurance (2026)OBBBA $15M/$30M framing; ILITs and estate liquidity — curl 200, 19 Oct 2026.