By Erik Berge | Senior Wealth Strategist, Citizens Private Wealth

For families with significant assets, understanding how and when federal transfer taxes may apply is essential to preserving assets across generations. Without proper planning, these taxes applied during life (Gift Tax1), at death (Estate Tax2) or to "skip" beneficiaries like grandchildren (Generation-Skipping Transfer Tax3), can significantly reduce what heirs receive. Additionally, transfers of cash, real estate, investments, business interests and other property may all be subject to transfer taxes.
Federal estate and gift taxes operate under a unified system,4 meaning both taxes are subject to the same lifetime exemption, which is $13.99 million5 per person in 2025 and increasing to $15 million in 2026 under the One Big Beautiful Bill Act, with annual inflation indexing thereafter. The lifetime exemption determines the unified credit used to reduce or eliminate transfer tax liability. Gifts made during life reduce the available exemption and must be reported by the individual making the gift on Form 709 to track cumulative use. No tax is owed until the exemption is fully used; after that, additional transfers are taxed at a "flat" 40% rate.6 At death, any remaining exemption is applied to offset estate tax, with the same 40% rate applying to amounts above the exemption.7
The generation-skipping transfer (GSTT) was created to prevent families from avoiding estate tax by transferring wealth directly to grandchildren or other "skipped" recipients who are typically unrelated to the grantor and more than 37.5 years younger.8 The GSTT also applies to estate and gift transfers and follows the lifetime estate and gift tax exemption limits.
When making gifts during life, whether to allocate a GSTT exemption depends on the recipient.
Proper allocation ensures that the gift is protected from both gift tax and GSTT, preserving more wealth for future generations.
Determining the taxable estate begins with identifying the full scope of a decedent's assets and applying allowable deductions and exemptions. The taxable estate comprises all assets owned at death, including:
Calculation FlowTaxable Estate = Gross Estate - Deductions Tentative Tax is calculated on the Taxable Estate Final Estate Tax = Tentative Tax - Unified Credit |
Applicable deductions then reduce the amount of the gross estate. These may include:
What remains is further reduced by the unused portion of the lifetime estate and gift tax exemption. Only the amount exceeding this exemption is subject to federal estate tax. Taxable estates must file a Form 706 Estate Tax Return within nine months of the date of death. Any estate taxes owed are due at this time.10
A range of strategies can help manage estate tax exposure, gifting, trusts, charitable giving and exemption management:
| Gifting strategies |
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|---|---|
| Trust strategies |
Irrevocable trusts can remove assets from the taxable estate while preserving control over distributions. These structures may also offer creditor protection and long-term planning benefits.
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| Charitable planning |
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| Exemption portability |
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With today's historically high lifetime exemptions, fewer estates are subject to estate, gift, and GSTT. As a result, income and capital gains tax strategies have become central to maximizing after-tax wealth transfer. Coordinated planning between benefactors and heirs can help align these strategies.
Today's historically high exemptions offer meaningful opportunities for efficient wealth transfer. But effective planning still demands coordination, timing and a clear understanding of how exemptions, taxes and family goals intersect. While the tools are familiar (lifetime gifting, trusts, charitable giving and income tax strategies), their value lies in how they are applied to each family's unique situation. The thoughtful and intentional integration of lifetime and legacy strategies remains one of the most effective ways to preserve wealth.
For additional guidance on strategies for estate and gift taxes, reach out to an experienced wealth manager from Citizens Private Wealth.
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1 IRC § 2501-2524
2 IRC § 2001-2210
3 IRC § 2601-2664
4 IRC § 2010
5 IRC § 2631(c)
6 While the federal estate tax rate is commonly referred to as a flat 40%, this is actually the top marginal rate applied to taxable estates. The tax is progressive, with lower rates applying to the first portion of taxable transfers. The 40% rate currently applies to amounts over $1 million in taxable estate value, after the exemption has been used. (See IRC §2001(c))
7 IRC § 2641
8 IRC § 2613
9 IRC § 2042
10 IRC § 6075(a)
11 IRC § 2503(b)
12 IRC § 664
13 IRC § 1014
Citizens Private Wealth does not provide legal or tax advice. The information contained herein is for informational purposes only as a service to the public and is not legal advice or a substitute for legal counsel. You should do your own research and/or contact your own legal or tax advisor for assistance with questions you may have on the information contained herein.
Citizens Wealth Management (in certain instances DBA Citizens Private Wealth) is a division of Citizens Bank, N.A. ("Citizens"). Securities, insurance, brokerage services, and investment advisory services offered by Citizens Securities, Inc. ("CSI"), a registered broker-dealer and SEC registered investment adviser - Member FINRA/SIPC. Investment advisory services may also be offered by Clarfeld Financial Advisors, LLC ("CFA"), an SEC registered investment adviser, or by unaffiliated members of FINRA and SIPC providing brokerage and custody services to CFA clients (see Form ADV for details). Insurance products may also be offered by Estate Preservation Services, LLC ("EPS") or an unaffiliated party. CSI, CFA and EPS are affiliates of Citizens. Banking products and trust services offered by Citizens.
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