Big Beautiful Bill: Big Promises, Bigger Blind Spots

The US just passed a major estate planning law.

It’s called the “One Big Beautiful Bill”, and if you manage wealth for international families with US ties—or even if you don’t—it’s worth paying attention.

Here’s what’s changed. More importantly, here’s what still hasn’t—and where the real risks (and opportunities) lie.

1. The $15M Exemption Is Now Permanent

But that’s not the whole story.

The new law makes the $15 million estate, gift, and GST exemption permanent starting 2026 (with inflation adjustments).

This sidesteps the feared “sunset” that would’ve cut the exemption to ~$7M.

But let’s be honest.

Most ultra-high-net-worth families in Asia already structure their assets well beyond $15 million.
And many have little or no direct US exposure.

So should you even care?

Actually—yes.

Because while this new law reduces estate tax risk for some, it does nothing to address:

• Wealth visibility across borders

• Asset protection from creditors or governments

• Income tax drag and succession delays

• Global compliance burdens (e.g. CRS, FATCA)

These issues are now the #1 concern for UHNW families, especially in China, Indonesia, Malaysia, and Singapore.

2. The Real Message? Add Flexibility. Build Optionality.

The bill doesn’t just raise exemption levels.
It sends a bigger message: planning must be more flexible.

Top US advisors are shifting to:

• Trust Protectors to adapt structures when laws change

• Spousal Lifetime Access Trusts (SLATs) to keep liquidity in the family

• Lifetime powers of appointment to reassign beneficiaries if needed

Why? Because tax laws change.
Family dynamics evolve. Portfolios shift. And rigid structures fail.

But here’s the problem: many traditional trust structures in Asia lack this flexibility—especially when designed years ago.

This is where many family offices get stuck.

The family wants privacy, control, and simplicity—but the solution feels overly complex or outdated.

3. Income Tax Planning: Non-Grantor Trusts Are Back…

But they’re not always practical.

The new bill also changes how deductions work.

It raises the standard deduction to $31,500 for married couples, making it harder to benefit from charitable giving or mortgage interest unless itemized.

Some advisors are recommending non-grantor irrevocable trusts to manage high-income assets and regain tax benefits.

But if you’ve ever tried using non-grantor structures, you know they’re operationally heavy:

• Extra tax filings

• Loss of grantor benefits

• More legal oversight and setup costs

Not ideal if your client wants simplicity, control, and cross-border portability.

Why PPLI Still Outperforms — Even in a “High Exemption” World

Now that the dust has settled, many advisors are asking: “If there’s no estate tax risk, should we still consider PPLI?”

The answer is an emphatic yes. And here’s why:

1. True Confidentiality — Even Outside the US

The “Big Beautiful Bill” affects US estate tax rules. It doesn’t shield your client from:

• CRS automatic reporting

• Government asset inquiries

• Multi-jurisdictional estate disputes

A properly structured PPLI (especially with zero cash value and non-reportable policy) sits outside CRS and FATCA—and outside the visibility grid.

This is particularly important for families with entities in BVI, Guernsey, Hong Kong, Dubai, or those acquiring overseas real estate and second residencies.

2. Built-In Flexibility Without Complexity

While the article recommends adding protectors, SLATs, and POAs to trusts—PPLI already offers:

• Control via Power of Attorney (not trustees)

• Change of insured across generations (no inheritance trigger)

• Access via escrow or asset exchange, not rigid distributions

It gives more flexibility with less legal burden, especially for families that want liquidity without giving up protection.

3. No Need to “Use” the Exemption — Just Remove the Asset from the Equation

With PPLI, there’s no need to gift, no need to trigger capital gains, and no need to burn your exemption.

You simply wrap the asset (cash, equities, even property) into a compliant insurance structure—and legally remove it from the estate.

That’s a different paradigm. And one many advisors in Asia are just starting to appreciate.

Final Thoughts for Advisors & Family Offices

If your clients value discretion, control, and long-term tax efficiency—PPLI is still your most powerful planning tool.

Especially when it’s structured right.

Like what you’ve read?

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“Why Ultra-High-Net-Worth Families Are Moving to PPLI”