One year of the OBBBA: How advisors are replanning around its biggest provisions

One year of the OBBBA: How advisors are replanning around its biggest provisions
From left: Keith Fenstad, Christopher Castellano, Andrew Kulha
Three advisors explain what the permanent $15M estate exemption, expanded QSBS rules, and new SALT cap are actually changing — and what most clients are still missing
JUL 23, 2026

July 4, 2026, marked the one-year anniversary of President Trump's signing of the One Big Beautiful Bill Act — the sweeping tax and spending legislation that made permanent the individual income tax brackets established by the 2017 Tax Cuts and Jobs Act, raised the federal estate, gift, and generation-skipping transfer (GST) tax exemption to $15 million per individual indexed for inflation beginning in 2027, lifted the SALT deduction cap to $40,000 for taxpayers with modified adjusted gross income below $500,000, restored 100% bonus depreciation for qualified property placed in service after January 19, 2025, created a new $6,000 above-the-line deduction for taxpayers age 65 and older, and significantly expanded the Qualified Small Business Stock exclusion under IRC Section 1202.

For advisors, 2026 is the first full year all of these provisions are in effect simultaneously — and the planning implications are still being digested. Three advisors describe the provisions that have changed their client conversations most, which ones remain underused, and what the new environment means for Roth conversion strategy.

The permanent estate exemption removed urgency — not the need for strategy

Keith Fenstad, director of wealth planning and chief compliance officer at Tanglewood Total Wealth Management, says the provision that surfaces most often with clients is the now-permanent $15 million estate and gift tax exemption.

Before the OBBBA, advisors and clients faced what Fenstad describes as a "use it or lose it" planning environment — the TCJA exemption was scheduled to revert to approximately $7 million per person at the end of 2025, creating urgency around large gifting strategies and irrevocable trust structures. That urgency is gone. Fenstad says he now has more breathing room to plan deliberately and make decisions in the right sequence rather than rushing to act before a sunset date.

"We are glad to have some greater visibility and confidence of the tax brackets over the short run and continue making tactical Roth conversions for those clients where it makes sense. For many of our clients with large IRAs, the top of the 24% bracket is often the target. At that level, however, most of the other OBBBA tax benefits are phased out. No doubt, however, that we are having to consider the new rules and deductions when calculating the effective cost of a conversion," Fenstad said.

On the SALT deduction, Fenstad identifies an opportunity that he says is easy to overlook from year to year: the expanded $40,000 cap may now make deduction bunching more attractive for clients who previously had no reason to itemize. By timing state and local tax payments — property taxes in particular — to concentrate deductions into alternating years, clients can itemize in the bunched year and take the standard deduction in the off year, potentially capturing more total deductions over a multi-year period than either approach would provide in isolation. The execution requires advance coordination, since the timing of tax payments must be managed accordingly. 

QSBS is the most overlooked planning opportunity for founders and early investors

Christopher Castellano, managing director and East regional leader at Wealthspire Advisors, identifies Qualified Small Business Stock as the most underutilized planning opportunity created or enhanced by the OBBBA.

The OBBBA did not just preserve the QSBS exclusion under IRC Section 1202 — it materially expanded it. The legislation introduced graduated exclusion tiers tied to holding periods, increased the maximum per-issuer exclusion from $10 million to $15 million and indexed that figure for inflation, and raised the gross asset threshold that determines which companies issue eligible QSBS. The combined effect is that founders, early-stage investors, and certain private equity and venture-backed businesses have access to a significantly more valuable tax exclusion than existed under prior law.

"The potential benefits of QSBS are often overlooked in structuring a new business. The OBBBA didn't just preserve QSBS, it made it more attractive by introducing graduated tiers across holding periods and increasing the maximum exclusion to $15 million and indexing for inflation. The expanded QSBS rules should prompt founders and advisors to evaluate entity choice early in a company's life cycle since electing C corporation status can create significant long-term tax benefits," Castellano said.

Castellano also points to a trust planning strategy — commonly called QSBS "stacking" — in which families can multiply the available exclusion by transferring QSBS shares to properly structured trusts, with each trust potentially qualifying for its own per-taxpayer exclusion. The strategy requires careful attention to trust design and timing, but the magnitude of the potential tax benefit makes it worth examining for clients involved in early-stage companies. On Roth conversions, Castellano's approach has not shifted significantly, though he notes growing interest in the conversion opportunities created by Trump Account rollovers for young adults and 529-to-Roth rollovers for families with residual education savings. 

Roth conversions are now a multi-year exercise, not a race against a sunset

Andrew Kulha, partner and director of estate strategy at Mission Wealth, frames the OBBBA's most significant planning impact in terms of what it removed: the deadline pressure that had structured much of estate planning since 2021.

With the $15 million exemption now permanent and indexed for inflation beginning in 2027, families can shift from reactive, deadline-driven gifting to intentional, income-tax-aware wealth transfer planning. That shift, Kulha argues, actually opens better planning opportunities than the urgency of the pre-OBBBA environment did — because advisors can now optimize for asset selection and basis step-up at death rather than simply moving assets out of estates as quickly as possible to beat a sunset.

Kulha also highlights two charitable giving provisions that he views as underrecognized. For clients who itemize, the new 0.5% AGI floor on the charitable deduction means that charitably inclined clients must give more intentionally — bunching gifts into high-income years or using Donor Advised Funds strategically to clear the floor and capture the deduction. For the much larger segment of clients who do not itemize, the new above-the-line charitable deduction of $1,000 for single filers and $2,000 for married couples filing jointly provides a meaningful benefit that did not exist before the OBBBA.

"With the lower individual tax brackets extended, Roth conversions are no longer a race against the automatic TCJA sunset increase but can continue to be done intentionally as a multi-year planning exercise coordinated with RMDs, Medicare premium adjustments, QCDs, and potential tax impacts on future beneficiaries," Kulha said.

Kulha's framework for Roth conversion planning in the post-OBBBA environment — coordinating conversions with RMDs, IRMAA thresholds, qualified charitable distributions, and beneficiary tax planning rather than simply targeting a rate bracket — reflects the broader shift all three advisors describe: from reactive, deadline-driven planning to deliberate, multi-year strategy. The law has not reduced the complexity of planning. It has redirected that complexity toward questions that are actually worth answering carefully.

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