THE BARATELLI INSTITUTE · Mentoring at Scale
FOR HNW FAMILIES & THEIR ESTATE COUNSEL

The federal cliff moved. The state cliffs didn't.

OBBBA permanently set the federal exemption at $15M ($30M MFJ for 2026, indexed). Most HNW families read that and exhale. Then they discover that 12 states + DC tax estates with thresholds as low as $1M — and a couple of states tax inheritances regardless of estate value. This tool shows your real federal + state exposure at projected death-date estate value.

$15M
Federal exemption (single)
$30M
Federal exemption (MFJ)
12+1
States with estate tax
$1M
OR / MA threshold (lowest)
YOUR ESTATE
1
Your situation
2
Estate value
3
Federal exemption
4
State estate tax
5
Headroom & strategy
STAGE 1 OF 5

Your situation

Defaults are typical for a 62-year-old MFJ couple in Florida with $18M of net worth.

Defaults to life-expectancy gap. Most HNW families plan to either age 90 or to second-to-die for MFJ, whichever is later.
Net of consumption. For a couple still building wealth: 5-8%. For retirees drawing down: 0-3%.
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STAGE 2 OF 5

Current estate value

Total taxable estate. Lifetime gifts above the annual exclusion ($19K/donee in 2025) reduce the federal exemption — modeled separately on the next stage.

Fair market value. Includes any in-state real property — important because some states tax non-resident decedents on real property within the state.
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Brokerage, savings, after-tax accounts. Includes private investments, crypto, etc.
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Pre-tax retirement is doubly taxed at death — estate tax on full value, then income tax to heir on distributions (unless Roth). Often the worst asset class to hold for high-estate families.
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Operating business equity (S-corp, LLC, partnership). Subject to special valuation discounts (lack of marketability, minority interest) that can reduce reported value 25-40% in well-structured situations.
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Insurance you own personally is in your taxable estate. Insurance owned by an ILIT (irrevocable life insurance trust) is OUTSIDE the estate — one of the most-used planning tools for moderate-net-worth families.
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Art, classic cars, jewelry, collections, partnership interests, intellectual property.
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Subtracted from gross estate to compute taxable estate.
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STAGE 3 OF 5

Federal exemption used (lifetime gifts)

Lifetime gifts above the annual exclusion reduce your federal exemption $-for-$. The 2026 federal exemption is approximately $15M per person ($30M MFJ), indexed for inflation under OBBBA.

Total reported on Form 709 over your lifetime above the annual exclusion. If you've used $0 of lifetime exemption, enter 0. If you've already burned $5M of exemption via prior gifting, enter $5M.
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Same — your spouse's prior lifetime gift reporting (if MFJ).
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If you're a surviving spouse with portability elected on the deceased spouse's 706, you may have inherited unused exemption. Enter total inherited DSUE.
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Post-OBBBA permanent: $15M per person, indexed for inflation. The TCJA "sunset" cliff was eliminated by OBBBA. But Congress can change the law again — the field is editable to model alternative scenarios (e.g., "$7M sunset" or "$25M expansion").
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What OBBBA changed. The TCJA-era "sunset" that would have cut the exemption to ~$7M per person on Jan 1, 2026 was eliminated by OBBBA in July 2025. The exemption is now $15M per person (2026), inflation-indexed permanently. The "use it or lose it" urgency that drove a wave of 2024-2025 SLATs and DAPTs is largely gone for federal purposes — but state-level estate taxes (next stage) are unchanged and remain the binding constraint for many HNW families.
STAGE 4 OF 5

State estate tax overlay

12 states + DC have their own estate tax with thresholds far below the federal exemption. Six states have inheritance tax on non-spouse heirs. Most HNW families never analyze this layer until it's too late to plan around it.

The state-residency planning lever. A 28-year horizon with a $30M+ projected estate in Massachusetts (16% rate above $2M threshold) generates meaningfully more state estate tax than the same family in Florida. Pre-death residency change to a no-state-estate-tax state is one of the most-used planning levers — but it requires real domicile change (not just registration), typically 2-3+ years of demonstrable residency before death, and tax-counsel coordination. See the State Tax Migration tool for the income-tax piece.
STAGE 5 OF 5 · YOUR HEADROOM

Estate tax headroom

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Federal exemption usage at projected death

Projected estate value at death

Tax exposure breakdown

Recommendations

PAIRS WITH
Estate Planning & Death Guide · Trust Selector · State Tax Migration
The EPD Guide chapters on lifetime gifting strategies (DGT, GRAT, IDGT, SLAT, GRATs vs. CLTs), state-residency change for estate tax purposes, and the ILIT structure cover the implementation playbook. The Trust Selector tool helps pick the right vehicle. Subscribe to the library →
EPD GUIDE

The full estate-planning playbook — by email.

Lifetime gifting strategies, ILIT structure, dynasty trust mechanics, state-residency change for estate tax, the post-OBBBA permanent exemption regime, basis-step-up vs. carryover analysis, and the full toolkit for HNW families.

Federal estate tax modeled as 40% flat on amount above exemption (statutory). State estate tax modeled with state-specific top rates and thresholds; bracket structures are simplified to top marginal rates above the threshold. Inheritance tax states (PA, KY, NJ, MD partial) modeled with class-1 (lineal heir) rates. The 28-year planning horizon implicitly assumes growth net of consumption — the projection is sensitive to growth assumption. Estate-freeze techniques, GST exemption, and discount-valuation strategies (FLPs, FLLCs) materially alter outcomes for HNW families and are not modeled here. This is not legal or tax advice.
WANT THE METHODOLOGY BEHIND THIS TOOL?
This calculator is one chapter of Estate Planning Decoded.
The tool gives you the answer. The guide gives you the argument — the case law, the worked examples, the negotiation playbook, the cross-check tables, the exception cases. Read the chapter and you can defend your number to a board, a buyer, an examiner, or a counterparty.
The methodology behind this calculator is in Ch 1 The OBBBA Reset of the reference guide.
See the Guide → Browse all 22 guides
PROFESSIONAL DISCLAIMER · PLEASE READ

Educational and informational purposes only. This calculator and any output it produces are intended solely for general educational and decision-support purposes. They do not constitute investment, tax, legal, accounting, appraisal, lending, insurance, or any other professional advice, and they do not create a fiduciary, attorney-client, accountant-client, or advisor-client relationship of any kind.

Estimates based on your inputs. All results are estimates derived from the data and assumptions you provide. Tax law, accounting standards, regulations, market conditions, and the specific facts of your situation can materially change the answer. The Baratelli Institute, its affiliates, and any co-branding professional make no warranty of accuracy, completeness, currency, or fitness for any particular purpose, and disclaim all liability for decisions made in reliance on the output.

Consult your own qualified professionals. Before acting on anything calculated here, consult your own attorney, CPA, financial advisor, appraiser, lender, or other qualified professional licensed in your jurisdiction who has reviewed your specific facts and applicable current law. The Baratelli Institute is a publisher of practitioner reference material. It is not a registered investment adviser, broker-dealer, law firm, accounting firm, appraisal firm, or lender.

Co-branded versions: If a professional advisor's name and contact information appear on this tool, that advisor has elected to make the tool available to clients as a courtesy. Inclusion of an advisor's name does not constitute the advisor's endorsement of any specific result, nor does it transfer professional responsibility for the underlying methodology to that advisor. The disclaimer above applies regardless of co-branding.