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For years, high-net-worth families and their advisers have been planning around a looming deadline: The end of 2025, when a slate of favorable tax provisions from the 2017 Tax Cuts and Jobs Act (TCJA) were set to expire.
The uncertainty drove planning decisions, accelerated gifting strategies and kept estate attorneys busy.
Then came July 4, 2025 — and the One Big Beautiful Bill Act (OBBBA). Most of the headlines focused on the politics. I want to focus on the math — specifically, what this roughly 870-page overhaul means for those who’ve spent decades building wealth and now need to protect and transfer it efficiently.
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Here are the three provisions that should be at the top of your planning agenda right now.
1. The estate tax exemption just got a lot more breathing room
This matters more than most people realize. Before the OBBBA passed, there was serious concern in the planning community that the exemption could drop to approximately $7 million per person when the prior TCJA provisions expired.
That scenario would have created an immediate taxable estate for a large number of my clients. The $15 million number removes that urgency — but it doesn’t mean inaction.
Here’s the real question to ask your estate attorney: Does your current plan still make sense at $15 million, or were structures put in place specifically to hedge against a lower exemption? Some irrevocable trusts funded for that purpose may now be suboptimal. A review is warranted.
One historical footnote worth noting: In 2010, the estate tax was temporarily repealed entirely. George Steinbrenner — whose estate was valued at approximately $1.1 billion — passed that year with zero estate tax liability. The $15 million exemption isn’t that, but with inflation adjustments built in, it’s the most durable estate tax relief high-net-worth families have seen in decades
2. The Roth conversion window is now permanently open
The reduced federal income tax rates originally enacted under the TCJA are now permanent under the OBBBA. This is arguably the most consequential planning development in this bill for high-net-worth retirees.
For years, advisers cautioned clients doing Roth conversions to act quickly before the TCJA rates potentially expired. That urgency is gone — but the opportunity isn’t.
If you have significant assets in tax-deferred accounts (think $1 million or more in a traditional IRA or 401(k)), permanent lower rates change the math on multi-year Roth conversion strategies.
The question is no longer, “Should I convert before rates go up?” It’s, “What’s the optimal bracket-filling strategy over the next 10 years given permanent rates, my RMD schedule, and my estate plan?”
A married couple with $2 million in a traditional IRA, for example, could systematically convert into the 22% or 24% bracket each year — paying tax now at known, permanent rates rather than forcing their heirs into potentially higher tax brackets later. Run the numbers with your adviser before year-end.
While Roth strategy benefits virtually every high-net-worth retiree, the next provision is more targeted — and the fine print matters.
3. The SALT increase helps — but the fine print catches most high earners
Read the fine print carefully. The enhanced deduction begins phasing out at $500,000 of income and disappears entirely at $600,000 — reverting to the $10,000 cap. For most of my clients, this provision is largely irrelevant because their income exceeds the phaseout threshold.
There’s also a marriage penalty embedded in the structure: The $40,000 cap is identical for single and married filers, meaning two-income households effectively get half the benefit on a per-person basis compared to single taxpayers.One additional wrinkle for top earners: Under the OBBBA, those in the 37% bracket will find their itemized deductions effectively capped at a 35% benefit — a modest but real reduction worth factoring into your planning.
The clients who benefit most here are those with income in the $300,000–$499,000 range who itemize and live in high-tax states. If that describes you, the SALT increase represents real money — potentially $30,000 in additional deductions, which at the 32% bracket is roughly $9,600 in tax savings annually through 2029.
A bonus for those approaching or in early retirement: The senior deduction
One smaller provision worth flagging for clients aged 65 and older: The OBBBA includes a new $6,000 deduction per person for tax years 2025–2028. A qualifying couple could deduct up to $12,000.
The catch: It phases out entirely above $75,000 in modified adjusted gross income for single filers and $150,000 for joint filers. But for clients whose adult parents or recently retired family members fall under those thresholds, it’s worth a conversation.
The bottom line
The OBBBA makes many TCJA provisions permanent and introduces new planning leverage points — particularly around estate transfers and Roth strategies. The window to optimize isn’t closed, but the calculus has shifted.
