The One Big Beautiful Bill Act (OB3)
The One Big Beautiful Bill Act (OB3) made relatively modest estate tax changes but introduced significant income tax considerations—shifting the focus squarely back to basis planning. This session will examine strategies for securing full basis step-ups at the first death and, where possible, positioning for a second step-up through the use of Joint Revocable Trusts.
Todd will also analyze the recent amendments to the Massachusetts estate tax, including the elimination of the benefits of the Massachusetts-only QTIP election. He’ll discuss the practical implications of these changes, how existing MASS ONLY QTIP elections remain viable for pre-change estates, and the planning opportunities they still create in eliminating the QTIP from taxation in the surviving spouse’s estate.
While not a deep dive into income taxation, the session will address selected trust income tax issues relevant to practitioners navigating the intersection of estate and income tax planning in light of the new law.
Attendees will gain an updated framework for advising clients on basis optimization, trust structuring, and Massachusetts estate tax compliance in the wake of these legislative changes.