Three rule changes that actually bind

US estate exemption is now $15M per person, $30M per couple, permanent, effective 1 January 2026. Removing the sunset killed the deadline-driven gifting industry and raised the threshold at which complex estate structuring pays for itself.

QSBS was rewritten for stock acquired on or after 4 July 2025: per-issuer cap $10M → $15M, company asset ceiling $50M → $75M, and the holding period is no longer all-or-nothing — three years now gives a 50% exclusion, four years 75%, five years 100%. Shares issued before and after that date are now different assets with different optimal hold periods.

Private placement life insurance is under direct legislative attack for the first time. An 18-month Senate Finance minority investigation found at least $40B sheltered through PPLI, which is 0.003% of outstanding life policies, with no IRS reporting requirement at all. The Wyden bill introduced 13 April is unlikely to pass this Congress; the reporting gap can close administratively without it, and probably will first.