In 2026, a married couple can combine two $15 million GST exemptions to seed a dynasty trust with $30 million, paying no gift or transfer tax, as the basic exclusion amount rises from $13,990,000 in 2025. Because beneficiaries hold interests while the trustee holds title, the principal stays outside their taxable estates, the structure the Rockefeller family has used since 1934. By contrast, leaving $30 million outright to children and then grandchildren would shrink to $10.8 million after two generations at a 40% estate tax rate, losing $19.2 million. The article notes a trade-off: assets gifted during life keep the original cost basis instead of the step-up received at death, so low-basis assets are better kept in the estate. Missing the Form 709 GST exemption allocation filing alone could expose the entire trust principal to a 40% generation-skipping tax rate.
Summary written by Upside AI from the original article. Read the source for full details.
Original headline: The Rockefellers Will Pay No Estate Tax Again This Generation Because Nobody Technically Owns the Money . In 2026 One Couple Will Be Able to Seed the Same Trust With $30 Million .
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- The Rockefellers Will Pay No Estate Tax Again This Generation Because Nobody Technically Owns the Money . In 2026 One Couple Will Be Able to Seed the Same Trust With $30 Million .
The article argues that the Rockefeller family has used irrevocable trusts set up in 1934 to keep wealth out of estate taxes across generations, since beneficiaries hold interests while the trustee holds title. It says newer families must use their exemption to get comparable protection, because the generation-skipping transfer tax applies to trusts created after the grandfathered date. For 2026 the basic exclusion is $15,000,000 per person, so a married couple can combine exemptions to fund a dynasty trust with $30 million without gift or GST tax. By contrast, it calculates that leaving the same $30 million outright through two generations at a 40% estate tax rate would cost $19.2 million. The trade-off, it says, is that lifetime gifts keep the original cost basis instead of a step-up at death.
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