Wealthy families are making a final push to take advantage of major tax changes signed into law in July, with family offices racing to finalize estate planning, make charitable contributions, and structure investments before the calendar flips to 2026. 
These changes include a permanently higher exemption in the federal estate and gift tax, expanded benefits for qualified small-business stock, and major changes to charitable contribution and investment expense rules. 

The changes mark a major shift for family offices, which have spent years bracing for the 2025 sunset of Trump-era tax cuts. Now, with permanent higher exemptions and new investment incentives in place, wealthy families can focus on long-term planning — but they still face year-end pressure to lock in certain benefits before new restrictions take effect in 2026.
The changes stem from the One Big Beautiful Bill Act (OBBBA), signed in July, which modified several provisions of the 2017 Tax Cuts and Jobs Act (TCJA). The changes largely benefit wealthy investors and families, who started the year anxious due to the expiration of key tax advantages implemented during President Donald Trump’s first term and now are ending the year thankful for the certainty brought by the OBBA’s provisions.   

These changes shift family offices from short-term, sunset-driven planning to longer-term structural optimization, said Kyle DePasquale, managing director and a partner at Rothschild Wealth Partners in Oak Brook, Illinois.

“With higher transfer tax exemptions, stable income tax rules and improved incentives for private business investment, families can focus on multigenerational planning rather than reacting to annual deadlines,” DePasquale said. These changes “set the stage for a more predictable and strategic tax environment for family offices.”

That’s if they take advantage of these new provisions. The biggest mistake that family offices make is not using the strategies and exemptions available to them, said Asher Rubinstein, a tax, asset protection, and trusts and estates attorney at New York-based Gallet Dreyer & Berkey. 

Here are some of the key changes and planning strategies:

The permanent increase in the gift and estate tax exemption 

This is one of the most consequential changes. Under the 2017 Tax Cuts and Jobs Act, the exemption was scheduled to be cut roughly in half at the end of 2025. The new legislation instead raises it to $15 million per individual or $30 million for married couples, with inflation indexing starting in 2027.

“For family offices, this means wealth transfer and succession planning can now proceed with more certainty, fewer forced asset sales and greater flexibility for estate structuring across generations,” said DePasquale. 

The change removed building pressure among wealthy families to exploit the prior exemption and transfer wealth by the end of 2025, said Rubinstein. “My end-of-the-year plea to my clients was always, ‘Use it or lose it,’ and this summer’s change took away that time urgency,” he said. “Now families have more time to think about their giving and their estate planning.”\

New tiers for qualified small-business stock

The new rules strengthen qualified small-business stock (QSBS) — a powerful tool for entrepreneurs and early-stage investors — since it enabled them to exclude $10 million from capital gains tax when selling qualified stock of a domestic C corporation that has been held more than five years. Now, that exclusion has been increased to $15 million, indexed for inflation, for QSBS issued after July 4, 2025, and the law introduces partial exclusions starting in year three.

That change has prompted family offices to adjust their investing strategies, since it makes gains from investments in qualifying businesses more attractive, said Claudia Sotolongo Gonzalez, a principal at Kaufman Rossin’s Tax Services Advisory Group. “This change has prompted more family offices to make those investments in small business, especially in new tech companies,” she said. “The QSBS is a great vehicle for that.”

Some family offices have maximized this strategy by having several members make such investments, with each setting up a separate nongrantor trust that also makes investments, said AK Moody, senior wealth strategist at BNY Wealth. “Then you can exponentially multiply the amount of gain you’re allowed to exclude,” she said, adding, “It becomes exceedingly powerful.”

The change has also incentivized businesses, including family-run firms, to restructure their company to qualify for such investments, said Tricia Levin, head of family office services for Brown Brothers Harriman’s multifamily office. In recent months, Levin said, she has talked with business owners who have explored converting their company to a C corp to take advantage of the new rule and attract more investors. 

“They are contemplating it and having those discussions because of the beneficial rules that are out there today,” Levin said. 

Changes to charitable deductions 

Rules for charitable giving also changed in ways that alter both the timing and strategy for wealthy donors. The law permanently extended the higher 60% adjusted-gross-income (AGI) limit for cash contributions to public charities. At the same time, it introduced a new floor requiring charitable deductions to exceed 0.5% of AGI beginning in 2026, creating fresh incentives to act sooner rather than later.

As a result, family offices are adopting philanthropic strategies like “bunching” contributions into a single year by parking their donations in a donor donor-advised fund (DAF), charitable remainder trust (CRT) or  similar vehicle to avoid the AGI floor and parcel out contributions at their leisure.

“It has caused people to accelerate some of their charity planning,” said Levin, “whether it’s lumping it all into 2025 or thinking more carefully about what their charitable giving is going to be for the next five years.”

Gonzales said she’s advising clients, whether they have DAFs or CRTs or not, to “just get the money out and make a donation before the end of December.” It’s likely too late to set up those vehicles before year-end if donors don’t already have them, she said, “so just give what you can.”

Other business and investment-related provisions 

Several provisions have also drawn attention, including the reinstatement of 100% bonus depreciation for eligible property acquired after Jan. 19, 2025, up from the 40% limit that had been in place, as well as the permanent extension of the 20% qualified business income (QBI) deduction for certain pass-through entities.

“We saw a lot of business owners put assets into service in 2025 because they thought they were only going to get a 40% bonus depreciation deduction,” Levin said, “and now they’re able to potentially get 100%.” 

That has led some people to consider buying expensive items like an aircraft to take advantage of this provision. Levin cautioned against letting tax benefits drive business decisions outright. 

“I personally don’t think that you should buy an airplane just for the tax deductions,” he said. “But I’ve had conversations with several business owners that were contemplating it,” given the ability to deduct the full cost of the plane in the year it is placed into service and thus offset ordinary income from the business.

Such changes, as well as the restoration of full expensing for domestic research and development costs, could also benefit companies seeking ways to “offset some of the pain they felt with tariffs,” said Moody of BNY Wealth. 

“Sometimes it's not worth spending a dollar to save 37 cents,” he said. “But in some cases, when the need is there, it makes sense to go ahead and put money into those types of expenses that will ultimately end up with a deduction.”

Weakened IRS not likely to pursue the wealthy 

The changes in tax policy depend on the enforcement of these rules by the IRS, which has continued to focus on tax compliance among high-income taxpayers and family offices, including campaigns targeting areas like losses in the sports industry and the personal use of corporate jets. But Jason Wiggam, a founding partner at Atlanta-based Wiggam Law, said the agency saw major layoffs of auditors this year, and “next year there will probably be less audits.”

Wiggam expects that “the campaign to target high-income, high-net-worth individuals and families is probably going to be abandoned. I don’t think that’s a priority of the current administration.”