Restructuring Family Offices Under New Tax Law: Key Changes
Explore how family offices are adapting to the new tax law, focusing on interest limitations and trust structures.

The recent enactment of the permanent $15 million estate tax exemption significantly alters the landscape for family offices. This change offers strategic advantages for wealth transfer and tax planning.
The One Big Beautiful Bill Act (OBBBA) has permanently increased the estate, gift, and generation-skipping transfer tax exemption to $15 million per individual, effective from 2026. This replaces the Tax Cuts and Jobs Act (TCJA) exemption, which stood at $13.99 million in 2025, according to RSM US. This is a significant development for family offices as it provides a clearer framework for wealth management and estate planning. For insights on how family offices can adapt to these changes, consider exploring direct investing strategies for family offices in 2026.
Starting January 1, 2026, the federal exemption will be set at $15 million per individual and $30 million per married couple, indexed to inflation from 2027 using 2025 as the base year, as reported by Harter Secrest & Emery. Unlike the TCJA increase, the OBBBA increase carries no sunset provision. This permanence allows family offices to engage in long-term planning without the uncertainty that previously loomed over the estate tax landscape.

With the new exemption in place, family offices must consider how to leverage this change in their wealth transfer strategies. The removal of the 2026 cliff allows for more proactive estate planning, enabling families to make gifts without the fear of a drastically reduced exemption in the near future. This stability empowers family offices to engage in more sophisticated financial strategies, potentially including:
As the wealth landscape changes, understanding the nuances of estate tax laws becomes crucial. Proactive family offices are already revisiting their estate plans to incorporate these new provisions. Additionally, the evolving landscape of private credit in family offices may also play a role in their investment strategies.
While the term “permanent” in tax law suggests stability, it is essential to recognize that tax legislation can change. As Andrew Schneider, Founder & CEO of Family Office Networks, noted,
This highlights the importance of staying connected and informed within the family office community to navigate potential changes in legislation.“The best opportunities in this world are never advertised — they move through relationships. Our job is to be the room where those relationships form.”
— Andrew Schneider, Founder & CEO, Family Office Networks
Recent reporting from InvestmentNews indicates that advisors are already adapting strategies around the OBBBA’s provisions. The real impact of the permanent exemption will depend on ongoing political dynamics and potential future reforms.

The permanence of the $15 million estate tax exemption offers family offices a unique opportunity to reassess their long-term objectives. However, as financial landscapes evolve, family offices must remain agile and ready to adapt. Here are a few considerations:
In this context, family offices that prioritize flexibility and foresight will be better positioned to benefit from the permanence of the OBBBA. For more on effective documentation practices, see best practices for investment documentation.
The exemption allows individuals to transfer up to $15 million without incurring estate taxes, providing significant tax relief and planning opportunities.
Unlike previous laws, the OBBBA’s exemption is permanent and does not carry a sunset provision, allowing for long-term planning.
Family offices can increase lifetime gifts, establish trusts, and invest in tax-efficient vehicles to maximize the benefits of the exemption.
Yes, while the exemption is currently permanent, tax laws can change, so family offices should remain vigilant and adaptable.

Explore how family offices are adapting to the new tax law, focusing on interest limitations and trust structures.

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