Spotlight on Transfer Taxes: The High Cost of No Planning

By Jennifer Grammer, CPA, Whitley Penn and Cecily Bolding, CFP®, Northern Trust

With record-high estate tax exemptions set to expire at the end of 2025 barring action from Congress, more wealthy families are, understandably, focused on taking advantage of current exemption amounts to optimize their plans. While we broadly believe it is better to plan for all outcomes than attempt to predict the shape of future tax policy, we have prepared the following case study in an effort to simplify understanding of transfer taxes and shed light on a potential challenge that more Americans could face beginning in 2026. Note that in the example below, we use limits applicable to a married couple; the limits for individuals are halved.

Case Study: The Impact of Expiring Exemptions

A married couple with a gross estate — defined as the total value of their liquid and illiquid assets at the time of their passing — of no more than $28,800,0001 (assuming they have made no taxable transfers during their lifetimes) would not be subject to transfer taxes should they both pass before Dec. 31, 2025.

However: If the transfer tax exemptions sunset at the end of 2025 as currently anticipated, the couple would be facing a tax of $6,080,000 if they both survive until 2026 (see chart 2).

For the sake of illustration, consider the couple has the following balance sheet toward the end of 2025.

The couple understands that with their current balance sheet, their estate tax liability is $02. Assume, however, the couple passes away in early 2026 with an identical balance sheet.

In this example, the executor of the estate determines that 100% of the couple’s liquid assets will be needed to satisfy the estate tax of $6,080,000, leaving a balance of $1,080,000 — which will require illiquid assets to be sold. As we know, selling real estate during a recession, for example, would be suboptimal.

Had the hypothetical couple engaged in thorough financial planning ahead of their passing, the executor and their beneficiaries might have avoided this predicament. How could the couple have avoided this outcome, and what can we learn from it?

Case Study: The Impact of Expiring Exemptions

A married couple with a gross estate — defined as the total value of their liquid and illiquid assets at the time of their passing — of no more than $28,800,0001 (assuming they have made no taxable transfers during their lifetimes) would not be subject to transfer taxes should they both pass before Dec. 31, 2025.

However: If the transfer tax exemptions sunset at the end of 2025 as currently anticipated, the couple would be facing a tax of $6,080,000 if they both survive until 2026 (see chart 2).

For the sake of illustration, consider the couple has the following balance sheet toward the end of 2025.

The couple understands that with their current balance sheet, their estate tax liability is $02. Assume, however, the couple passes away in early 2026 with an identical balance sheet.

In this example, the executor of the estate determines that 100% of the couple’s liquid assets will be needed to satisfy the estate tax of $6,080,000, leaving a balance of $1,080,000 — which will require illiquid assets to be sold. As we know, selling real estate during a recession, for example, would be suboptimal.

Had the hypothetical couple engaged in thorough financial planning ahead of their passing, the executor and their beneficiaries might have avoided this predicament. How could the couple have avoided this outcome, and what can we learn from it?

Happy Caucasian couple checking their mail at home and smiling - domestic life concepts
Liquidity Matters

Clarity into your total balance sheet, including liquid assets, tangible personal property and illiquid assets, is the first step in understanding your potential estate tax obligation. This information, coupled with an understanding of your cash-flow needs, prepares you to have an informed, actionable financial planning conversation. If the couple in the case study had consulted a team of experienced advisors, they could have explored strategies to manage their liquidity and real estate concentration.

Titling Matters

Review entity structure and asset titling to consider moving appreciating assets out of your estate . Probate may be avoided, for example, by holding real estate assets in trust. Steps can also be taken to exclude trust assets from your taxable estate. Had the couple consulted with a team of advisors, they could have explored titling assets in trust and making gifts to manage their taxable estate.

Advice Matters

Wealth, tax and estate planning advisors work to stay informed of upcoming legislation. Think of this team as your personal board of directors. Had the couple in the case study met with a team of advisors, they could have proactively implemented a custom estate plan that supported their lifetime cash flow needs and minimized their estate tax obligation.

Liquidity Matters

Clarity into your total balance sheet, including liquid assets, tangible personal property and illiquid assets, is the first step in understanding your potential estate tax obligation. This information, coupled with an understanding of your cash-flow needs, prepares you to have an informed, actionable financial planning conversation. If the couple in the case study had consulted a team of experienced advisors, they could have explored strategies to manage their liquidity and real estate concentration.

Titling Matters

Review entity structure and asset titling to consider moving appreciating assets out of your estate . Probate may be avoided, for example, by holding real estate assets in trust. Steps can also be taken to exclude trust assets from your taxable estate. Had the couple consulted with a team of advisors, they could have explored titling assets in trust and making gifts to manage their taxable estate.

Happy Caucasian couple checking their mail at home and smiling - domestic life concepts
Advice Matters

Wealth, tax and estate planning advisors work to stay informed of upcoming legislation. Think of this team as your personal board of directors. Had the couple in the case study met with a team of advisors, they could have proactively implemented a custom estate plan that supported their lifetime cash flow needs and minimized their estate tax obligation.

Takeaways:

  • If you have a balance sheet with assets totaling $10M or more, this change is worth a planning discussion with your Even if the exemption amount is greater than your asset total today, assuming a conservative growth rate, you could be affected by transfer taxes by the time your estate tax comes due.
  • If you know you are holding an illiquid asset that has potential to significantly appreciate (e.g., real estate in a high-growth area), consider transferring this asset into a trust that is out of your estate.

Takeaways:

  • If you have a balance sheet with assets totaling $10M or more, this change is worth a planning discussion with your professional advisor(s).
  • Even if the exemption amount is greater than your asset total today, assuming a conservative growth rate, you could be affected by transfer taxes by the time your estate tax comes due.
  • If you know you are holding an illiquid asset that has potential to significantly appreciate (e.g., real estate in a high-growth area), consider transferring this asset into a trust that is out of your estate.

Contact a Professional

Jennifer Grammer

Senior Tax Manager, Whitley Penn

Cecily Bolding

Managing Director, Northern Trust

Cecily Bolding

Managing Director

References:

  1. This amount is an estimate of the amount that will be available in 2025. The exact amount of the exemption for 2025 has not yet been released. It will be based on an inflation adjustment to the 2024 amount of $13.61 million.
  2. This assumes they are residents of Texas and all of their real property is in Texas or another state that does not impose a state level estate tax.

**Indexed inflation amounts are estimated and subject to change. IRS issues inflation indexes each year.

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