Before the 2026 Tax Storm: 5 Moves UHNW Families Are Quietly Making to Lock In Today’s Rules

How do you protect a $100 million estate when the rules are about to change?

Because like it or not, the current tax code is expiring.
And for the ultra-wealthy, that quiet little detail could have massive consequences.

The 2026 tax storm isn’t a vague headline. It’s a countdown.

Estate exemptions? Shrinking.
Top tax brackets? Likely climbing.
Visibility? Only getting worse with each wave of global transparency.

Most clients won’t see it coming—until they’re hit with a much larger tax bill. Or worse, until a well-laid succession plan unravels under scrutiny.

But some families are moving now. Quietly. Strategically. Behind closed doors.

And the difference?

It’s not complexity. It’s timing.

Because 2025 is the last full year under the current tax code.
Once the window closes, it’s closed.

What’s Changing?

Unless Congress intervenes, major provisions from the Tax Cuts and Jobs Act (TCJA) will sunset by the end of 2025. That means:

• Higher income tax brackets

• Lower estate and gift tax exemptions

• Reduced deductions for high earners

For UHNW families and their advisors, the writing is on the wall:

2025 is your move.

Here’s what I’m seeing behind the scenes this year:

Some families aren’t waiting. They’re locking in today’s rules before they vanish.

And it’s not theory—I’ve watched them:

• Accelerate gains now to avoid a 39.6% tax surprise later

• Stack deductions while they still matter

• Re-evaluate trusts and SPVs that no longer hold up under CRS

• Wrap opaque, non-liquid assets—like PE, real estate, and crypto—in tax-efficient wrappers

• And reposition while they still can, because they know the window won’t stay open long

If you’re advising families at this level, here are 5 moves I’m urging every partner and client to make now—not later.

5 Moves to Stay Ahead of the Curve

1. Get a Handle on the Numbers

No strategy works without clean data.

That means:

• Tight bookkeeping

• Real-time visibility across entities

• Clarity on income, deductions, liabilities

One client had 30+ entities across five countries. Turns out, a forgotten legacy trust was triggering avoidable CRS exposure. We caught it early—because their numbers were finally clear.

2. Reassess Life Events

Marriage. Divorce. Exits. Relocation. These aren’t just personal—they’re structural.

And in families operating across Asia, the Middle East, and Europe, even small changes can trigger big compliance issues.

In 2025, every life event is a planning opportunity. Ignore it, and the exposure quietly builds.

3. Time Income & Deductions Intentionally

The smartest families aren’t guessing what 2026 will bring. They’re already adapting.

They’re:

• Pulling forward bonuses and exits

• Bringing forward charitable contributions

• Creating liquidity on their terms

As one client put it: “I’d rather pay 20% now than 39.6% later.”

This isn’t about tax avoidance. It’s smart timing.

4. Leverage Donor-Advised Funds (DAFs)

DAFs used to be a nice-to-have. Now they’re a strategic lever.

They allow families to:

• Lock in deductions this year

• Disburse on their own timeline

• Keep philanthropy structured, discreet, and flexible

A family I worked with moved $5M into a DAF early this year—not just for the deduction, but to align long-term giving across multiple generations without complication.

5. Plan Like the Rules Will Change

If you’re waiting to “see what happens,” you’re already behind.

Families I work with are:

• Modeling scenarios where exemptions are slashed

• Preparing for a rise in global tax rates

• Rebuilding their structures for compliance and control

Because many tools will still exist in 2026. But the benefits?
They may be long gone.

Final Thought: Tax Planning Is No Longer Just About Tax

In today’s environment—where transparency is tightening and global coordination is increasing—tax planning is privacy planning.

That’s where Private Placement Life Insurance (PPLI) comes in.

Used properly, PPLI offers more than tax deferral:

• Confidentiality from CRS reporting

• Capital gains sheltering—without triggering disposal

• Seamless cross-border succession without probate or panic

If your clients are considering next-gen structures, 2025 isn’t just a deadline.

It’s a doorway.

And what they do now will define what they’re allowed to keep later.

Here’s what to do next:

Book a private consult, or subscribe to get the full whitepaper:

"Why UHNW Families Are Quietly Moving to PPLI"

Inside, I’ll show you how discreet families are reducing exposure, maintaining control, and passing on wealth—without relying on outdated tools.

No pressure. No sales pitch.
Just real insights you can use.

Let’s make sure your clients are protected before the storm hits.

— Donald