On July 4, 2025, President Trump signed the One Big, Beautiful Bill Act (OBBBA) into law. This landmark tax legislation makes permanent many provisions originally set to expire under the 2017 Tax Cuts and Jobs Act (TCJA), introducing several new deductions, and significantly reshaping the U.S. tax landscape.

At Morello Law Group, P.C., our advanced estate and tax planning practice is designed to help individuals and families navigate this complex new legislation with confidence. Our first priority is to understand your objectives, then work closely with you to implement a tailored estate plan that protects you and your family, minimizes your tax burden, and ensures your legacy is preserved according to your wishes.

Here is a summary of the key takeaways most relevant to estate, business, and personal tax planning.

Estate, Gift, and GST Tax: Higher Exemptions and Advanced Planning Overview

Under the One Big, Beautiful Bill Act, the federal estate, gift, and generation-skipping transfer (GST) tax exemption increases from $13.99 million per individual in 2025 ($27.98 million for married couples) to $15 million per individual ($30 million for married couples) beginning in 2026, adjusted annually for inflation. Although this change is labeled “permanent,” future administrations or Congresses may seek to reverse or limit these planning opportunities in the future, meaning proactive planning is essential.

For high-net-worth individuals and families, this creates a substantial opportunity to implement or revisit advanced wealth transfer strategies in order to preserve assets and reduce potential federal estate tax exposure in the future. For other individuals, an opportunity now exists to potentially simplify your planning while retaining all the tax benefits of previous more advanced planning. Attorneys at Morello Law Group can assist you in evaluating and, if appropriate, modifying or adding to your current estate plan.

At Morello Law Group, we assist clients with both comprehensive estate planning and with advanced wealth transfer strategies designed to help you move wealth out of your taxable estate to protect your assets, while still achieving your goals. Some advanced strategies that can be tailored to your specific needs and may include:

• Annual Gifting Programs that utilize the annual gift tax exclusion to transfer wealth efficiently year after year.
• Irrevocable Trust Structures, such as:
  • Irrevocable Life Insurance Trusts (ILITs) to remove death benefits from your estate and create liquidity.
  •  Irrevocable Gifting Trusts to combine tax benefits with control over future use and distribution.
  • Spousal Lifetime Access Trusts (SLATs) to provide for your spouse while removing growth from your taxable estate.
  • Grantor Retained Trusts like GRATs and GRUTs to reduce the taxable value of gifts while retaining income for a period of time.
  • Qualified Personal Residence Trusts (QPRTs) for leveraging your home’s value in a tax-advantaged transfer.
• Intentionally Defective Grantor Trusts (IDGTs), a powerful technique that allows the grantor to pay income taxes on behalf of the trust, further reducing their estate.
• Valuation Discounts for transfers of closely held business interests through entities such as Family Limited Liability Companies (FLLCs), which can significantly reduce taxable gift values while maintaining control.
• Charitable Planning Options, including Charitable Remainder Trusts (CRATs/CRUTs), which can generate income, offer charitable deductions, and ultimately reduce estate and income tax exposure.

Each of these estate planning techniques can play a vital role in an estate plan tailored to meet your tax objectives, personal wishes, and long-term goals. Given the increased exemption amounts, now is an ideal time to explore these strategies with an experienced estate planning attorney at Morello Law Group, P.C.

Business Planning Under the One Big, Beautiful Bill Act

Significant updates to business tax law were also enacted under OBBBA, creating key opportunities for business owners to optimize tax efficiency and plan for succession or wealth transfer.

I. The Qualified Business Income Deduction

One of the most important takeaways for small business owners is that the 20% deduction for Qualified Business Income (QBI), originally enacted under the 2017 Tax Cuts and Jobs Act, is now permanent. This deduction allows qualifying pass-through businesses (LLCs, S Corporations, partnerships, and sole proprietorships) to deduct up to 20% of their QBI from taxable income, subject to certain limitations. The notable changes include:

• The income phase-in thresholds have increased to $150,000 for joint filers and $75,000 for single filers.
• A new minimum $400 deduction is available for taxpayers with at least $1,000 of qualifying income.
• Specified service businesses, which previously faced significant limitations, will now enjoy expanded eligibility under more generous income thresholds.

Business owners should reevaluate how their businesses are structured and how compensation is drawn to ensure they are optimizing this deduction under the new law.

II. Qualified Small Business Stock (QSBS)

The rules governing the sale of Qualified Small Business Stock (QSBS) have also changed in ways that may encourage longer-term equity holding and intergenerational planning. Under the new tiered system:

• 50% of gain is excluded for QSBS held at least 3 years,
• 75% for stock held 4 years; and
• 100% exclusion for stock held 5 years or more.

Additionally:

• The aggregate gross asset test for the issuing corporation increases from $50 million to $75 million.
• The per-issuer gain exclusion cap rises to $15 million, adjusted annually for inflation.

These updates present an opportunity for business owners to integrate QSBS into estate planning strategies.

III. Additional Business Incentives and International Tax Updates

OBBBA includes a number of provisions aimed at encouraging business investment and simplifying global tax exposure. Key changes include:

• The permanent reinstatement of 100% bonus depreciation, and an increase in the Section 179 expensing limit to $2.5 million.
• The permanent extension of Opportunity Zone tax benefits, with revised rules for deferral and basis increases.
• Enhanced credits for family and medical leave, along with more restrictive rules on employee retention credits (ERCs).
• Expanded international tax provisions affecting foreign-derived intangible income (FDII), GILTI, BEAT, and sourcing rules for cross-border income.

These changes are highly technical but may provide significant tax relief for certain industries, particularly those with overseas operations or long-term capital investment needs.

IV. What This Means for Closely Held Business Owners

Now more than ever, owners of closely held businesses should be evaluating how to leverage these new tax changes for both income tax efficiency and long-term estate planning. At Morello Law Group, we assist clients with potential advanced wealth transfer strategies tailored to your specific needs, such as:

• Recapitalization strategies that allow owners to gift nonvoting interests to family while retaining control
• Use of valuation discounts to reduce the gift tax impact of transferring closely held shares
• Integration of new QSBS provisions into irrevocable trusts, dynasty trusts, or IDGTs to maximize long-term wealth transfer

Again, while many provisions of the OBBBA are described as permanent, future administrations or Congresses may seek to reverse or limit these planning opportunities. If you own a business or hold closely held stock, now is the time to act. The attorneys at Morello Law Group, P.C., understand the complexities of business structuring, tax law, and advanced estate planning. Whether you’re considering reorganizing your business, selling stock, or transferring assets to family members, we can help you evaluate your options and implement a strategy tailored to your goals.

What the One Big, Beautiful Bill Act Means for Your Personal Income Taxes

With the enactment of the One Big, Beautiful Bill Act (OBBBA), major changes were made to the U.S. income tax code, some permanent, others temporary but still highly impactful. These changes will affect nearly every taxpayer, from working professionals and retirees to high-net-worth families and business owners.

At Morello Law Group, P.C., our goal is to help you understand how these new laws interact with your overall estate and tax planning strategies. Below is a summary of the most significant changes to individual income tax law under OBBBA, and what they may mean for your planning going forward.

I. Income Tax Rates Made Permanent

The income tax brackets first introduced in the 2017 Tax Cuts and Jobs Act (TCJA) are now permanently extended. The lower rate structure: 10%, 12%, 22%, 24%, 32%, 35%, and 37% remains in place, with income thresholds adjusted annually for inflation.

• The standard deduction increases to $15,750 for single filers and $31,500 for joint filers in 2025, adjusted for inflation.
•  Personal exemptions remain eliminated, consistent with prior law.

These changes provide greater long-term planning stability, allowing taxpayers to more confidently structure income timing, retirement withdrawals, and charitable giving strategies.

II. SALT Cap Relief and Other New Deductions

The bill temporarily raises the State and Local Tax (SALT) deduction cap to $40,000 for taxpayers earning less than $500,000, effective through 2029. After that, the cap returns to $10,000.
In addition, several temporary deductions (available through 2028) were added:

• Tip Income Deduction: Deduct up to $25,000 in tip income (non-itemizers eligible). Phase-out begins at $150,000 modified adjusted gross income for single filers, $300,000 for joint filers. Certain specified service businesses are excluded.
• Overtime Pay Deduction: Deduct up to $12,500 (or $25,000 for joint filers) in qualifying overtime income, subject to the same income limits.
• Car Loan Interest Deduction: Deduct up to $10,000 in interest for cars assembled in the U.S. (Phases out at $100,000 for single filers; $200,000 for joint filers.
• Senior Deduction: Taxpayers aged 65 and older receive a $6,000 additional deduction, phasing out at $75,000 (single) or $150,000 (joint filers).

III. Charitable Deduction Enhancements

• Non-itemizers may now deduct up to $1,000 (single) or $2,000 (joint) in charitable contributions starting in 2026.
• Itemizers may only deduct charitable gifts exceeding 0.5% of their adjusted gross income. Contributions below this threshold are nondeductible, and new limitations also apply to carryforwards.

This change stresses the importance of strategic giving, particularly for those near the itemization threshold or those who give large gifts in certain years.

IV. Alternative Minimum Tax (AMT) Exemption Expansion

The AMT exemption is permanently increased to $500,000 for single filers and $1,000,000 for joint filers, indexed for inflation. Additionally, the phaseout rate increases from 25% to 50%, reducing AMT exposure for many taxpayers.

V. Planning Implications and Next Steps

Although many of these provisions are favorable to taxpayers, they also introduce complexity—particularly for those near phaseout thresholds or with fluctuating income. At Morello Law Group, we believe tax planning should be personalized. Whether you’re nearing retirement, navigating charitable giving, or simply looking to reduce your annual tax burden, we can help you assess how these provisions apply to your unique situation and integrate them with your broader estate and financial plans.

Planning Considerations

The OBBBA implemented many taxpayer-friendly provisions and introduced new planning opportunities for individuals, families, and businesses.

High-net-worth individuals and families should review estate plans in light of the higher federal estate, gift, and generation-skipping transfer tax exemption increases.

Business owners should revisit entity structures and compensation strategies to fully capture the qualified business income and qualified small business stock benefits.

Charitably inclined individuals should reevaluate their giving strategies to meet the new deduction thresholds.

This is just a brief overview of the One Big, Beautiful Bill Act and some of its potentially far-reaching tax and estate planning implications. View the full bill here. Please be advised that this overview does not address all the changes contained in this extensive bill and is for informational purposes only and does not constitute personalized tax advice. Every individual and family will be impacted differently based on their unique circumstances, goals, and financial structures. At Morello Law Group, P.C., we take the time to understand your specific objectives before offering solutions. Whether you’re a business owner looking to leverage new deductions, a family considering wealth transfer strategies, or simply want to ensure your existing plan remains effective under this new law, our estate planning attorneys are here to help.

Please contact Morello Law Group, P.C., at (248) 347-2950 to schedule an appointment. One of our experienced attorneys will work closely with you to ensure that your estate plan reflects both the latest legal changes and your estate planning objectives.

Contact Us

 

Authors: Ryan J. Plantrich and Noah J. Christie

Learn more about the author, Ryan J. Plantrich. Learn more about the author, Noah J. Christie.