Most of what has been written about the One Big Beautiful Bill Act and its effect on estate planning is incomplete. The headlines say the cliff was avoided, the exemption is now permanent and indexed for inflation, and families who rushed to plan in 2024 and early 2025 can finally relax. That narrative is partly true. It is also dangerously thin. At Avion Wealth, we are already seeing this dynamic surface across estate plan reviews. The urgency has disappeared. The complexity has not.
For families who spent the last eighteen months executing SLATs, GRATs, intentional grantor trusts, and substantial gifting programs under deadline pressure, the question is no longer whether the work was completed. It is whether the work was completed well. A plan built around a deadline that no longer exists deserves a fresh look, not because the prior work was wrong, but because the planning landscape has shifted and the relevant questions have shifted with it.
There are three areas that may deserve a closer look.
1. Irrevocable Trusts Drafted on Crisis-Mode Timelines
Speed and structural precision are not always compatible. Trusts executed in the final months before the prior sunset were often drafted to meet a deadline, not to optimize for a multi-decade horizon. Provisions that seemed acceptable under pressure may not serve the family well across the next twenty or thirty years. In some cases, the structure is sound and no changes are warranted. In others, modest refinements may meaningfully improve long-term outcomes. These questions are easier to address now than after years of compounding.
Considerations may include:
- Whether trustee succession provisions reflect the family’s current and anticipated governance structure
- Whether distribution standards align with the beneficiary profile and long-term intent
- Whether the trust situs and applicable state law remain optimal given the family’s residency and asset mix
- Whether decanting, non-judicial settlement, or modification authority may be useful where flexibility is needed
- Whether grantor trust status, and the income tax responsibility that comes with it, remains aligned with the grantor’s broader cash flow plan
2. Assets Already Transferred Into Existing Structures
Once a transfer is complete, the assets begin appreciating inside the vehicle that received them. That vehicle may not have been optimally designed for the family’s actual goals. Reviewing these questions before the appreciation compounds tends to be more productive than reviewing them years later, when restructuring options are more constrained.
Considerations may include:
- Whether the asset mix inside the trust aligns with the trust’s intended distribution timeline and beneficiary needs
- Whether basis planning has been coordinated, particularly for assets where future step-up treatment may be relevant
- Whether the trust has sufficient liquidity to meet administrative obligations, tax responsibilities, and any expected distributions
- Whether the investment policy applied inside the trust is documented and consistent with fiduciary expectations
- Whether concentrated positions transferred under deadline pressure should be diversified, and on what timeline
3. Additional Planning Capacity Under the Permanent Exemption
This is the opportunity most clients have not yet been told about. Families who previously exhausted their exemption under the prior, lower figures may now make additional tax-free transfers under the higher, permanent figure.
For a Complex Entrepreneur with a growing balance sheet, that incremental capacity may represent meaningful additional planning room. Whether that capacity is best deployed, and how, depends on the family’s overall structure, liquidity profile, intergenerational goals, and the planning vehicles already in place. The answer is not automatic. The conversation, however, may be worth having before another planning cycle elapses.
Coordinating the Review
Your estate attorney may have closed the file. Your wealth advisor should open it again.
The Wealth Confidence Plan™ we build at Avion Wealth is not a one-time deliverable. It is a coordinated review across investment, tax, and estate considerations, run alongside your existing legal and tax professionals. Estate planning sits inside that integrated framework, not adjacent to it. When legislation changes, when assets appreciate, when family circumstances evolve, the plan is intended to be revisited with the same rigor it was built with.
A plan structured around a deadline that no longer exists deserves a fresh look. The deadline lifted. The questions did not.
A Complimentary Second Opinion
For families who completed significant estate planning in the past two years, Avion Wealth offers a complimentary Second Opinion Service focused on how recent legislative changes may affect existing structures and remaining planning capacity. The review is coordinated alongside your existing legal and tax professionals and is designed to surface questions worth exploring, not to displace decisions already made.
To your success,
The Avion Wealth Team
Sources
- Baker, Logan. “Estate Tax Exemption 2026 Changes Still Need 2025 Planning.” Mercer Advisors, September 30, 2025. https://www.merceradvisors.com/insights/trust-estate/estate-tax-exemption-2026-changes-still-need-2025-planning/
- “Estate tax changes for 2026 and beyond.” Thrivent, December 4, 2025 (revised February 6, 2026). https://www.thrivent.com/insights/estate-planning/estate-tax-changes-for-2026-and-beyond