On July 4, 2025, new legislation commonly referred to as the “Big Beautiful Bill” was signed into law. This law includes permanent changes to federal tax and estate planning provisions, many of which build on the framework established by the 2017 Tax Cuts and Jobs Act (TCJA). The bill affects key areas such as estate and gift tax exemptions, trust planning strategies, and the treatment of investment advisory fees.
Investment Advisory Fees: Permanently Non-Deductible
Under President Trump’s 2017 Tax Cuts and Jobs Act, investment advisory fees were no longer allowed as miscellaneous itemized deductions. The new “Big Beautiful Bill” legislation makes that change permanent.
These fees can add up quickly as client portfolios grow. Without deductibility, paying investment advisory fees personally or through a trust may result in significant lost tax benefits. However, there is a strategic alternative.
By using a Private Trust Company (PTC) to oversee investment activity, advisory fees may be reclassified as deductible business expenses under IRC §162.
Example: A client with $30 million AUM paying a 1% advisory fee ($300,000/year) cannot deduct this under a personal or trust structure. However, if those fees are routed through a properly structured PTC, the net annual tax savings could be $80,000 to $120,000—while also gaining the operational and governance benefits of a family office.
This planning tool is no longer limited to the ultra-high-net-worth segment.
No Sunset of the Federal Estate and Gift Tax Exemption
Previously, the expanded federal estate and gift tax exemption was scheduled to expire in 2026. The “Big Beautiful Bill” makes this increased exemption permanent, eliminating the timing pressure that had been associated with the expected sunset provision.
As of 2025, the exemption stands at $13,990,000 per person, or $27,980,000 per married couple, and will now continue at this level (adjusted for inflation) indefinitely unless changed by future legislation.
Core Trust Planning Strategies Remain Intact
The bill preserves key irrevocable trust tools, including:
These remain central to tax-efficient multigenerational planning.
The “Trump Account” for Minors
The bill introduces a new vehicle for young investors: the Trump Account– a tax-advantaged investment tool for minors.
This is not a replacement for 529 plans or UTMA accounts, but serves as a complementary tool for forward-thinking families.
At Hargrove Firm, we navigate complex estate planning landscapes, especially when new legislation introduces strategic opportunities. The Big Beautiful Bill has reshaped the planning timeline and approach for many families, and advisors must be ready to respond with clarity and expertise.
Whether your client is reassessing estate tax exposure given the permanent exemption levels, considering enhanced trust strategies, or curious about how new tools like the Trump Account may apply to their legacy planning, Hargrove Firm is here to help.
Hargrove Firm attorneys work alongside advisors to ensure their clients’ plans are compliant, tax-efficient, and forward-thinking. If you’d like to discuss how these legislative changes may affect your clients’ estate plans or want to explore how to implement these strategies effectively, connect with our team.