Unlocking the Tax Trifecta Trust: Advanced Planning After the One Big Beautiful Bill Act

By Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) & Steven J. Oshins, J.D. AEP (Distinguished)

The Shift in Tax Planning: From Estate Tax to Income Tax Strategies

The One Big Beautiful Bill Act has reshaped the landscape of tax planning. With the federal estate and gift tax exemption at $15 million, estate tax planning has naturally become less urgent for many clients. But that doesn’t mean tax planning has lost importance — it has simply shifted focus.

Today, the real opportunity lies in income tax planning, and non-grantor trusts are rapidly emerging as the centerpiece of those strategies.

Why Non-Grantor Trusts Matter

Traditionally, trusts were thought of primarily in terms of estate planning — passing wealth efficiently to the next generation. But with estate taxes now less of a concern for most, the non-grantor trust provides a unique way to achieve income tax savings that can add up dramatically year after year.

Opportunities include:

• Income Shifting – Moving income to children or grandchildren in lower brackets to reduce the overall family tax bill.

• Expanding SALT Deductions – Taking advantage of the new, higher $40,000 limit available to both individuals and trusts.

• Maximizing Section 199A Deductions – Dividing income among multiple trusts to preserve valuable qualified business income (QBI) deductions.

• Stacking QSBS Exclusions – Structuring ownership to maximize capital gains exclusions under Section 1202.

• Saving State Income Taxes – Establishing trusts in jurisdictions with no state income tax to keep more wealth in the family.

Each of these strategies can be powerful on its own. But what happens when they’re combined?

The Power of Stacking Strategies

This is where the idea of the Tax Trifecta Trust comes in. Rather than relying on just one tax-saving opportunity, the Trifecta approach involves “stacking” multiple benefits together.

For example, a client might:

• Shift income to beneficiaries in lower brackets,

• While also creating a structure that qualifies for additional SALT deductions,

• And at the same time, unlock a new Section 199A deduction.

Suddenly, what looked like a modest benefit becomes a compelling, multi-layered planning strategy. In some cases, adding state income tax savings or QSBS planning creates even more significant results.

Why This Matters for Advisors and Clients

The days of focusing almost exclusively on estate tax planning are over—at least for now. With today’s high exemptions, income tax efficiency is where advisors can bring the most value. For high-net-worth clients in particular, the cumulative effect of these strategies can represent hundreds of thousands of dollars in savings over time.

The Tax Trifecta Trust isn’t a “one-size-fits-all” solution. Every family’s circumstances, goals, and state residency rules are different. But for advisors willing to explore creative planning with non-grantor trusts, the opportunities have never been greater.

Looking Ahead

The One Big Beautiful Bill Act may have reduced the urgency around estate taxes, but it has opened the door to a renaissance in trust-based income tax planning. Whether through shifting income, leveraging deductions, or stacking multiple strategies, the non-grantor trust is quickly becoming one of the most powerful tools in the modern planner’s toolkit.

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ABOUT THE AUTHORS

Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. He can be reached at 920.593.1700 or [email protected]. His law firm’s website is www.keeblerandassociates.com.

Steve Oshins, J.D., AEP (Distinguished), is a member of the Law Offices of Oshins & Associates, LLC in Las Vegas, Nevada. He was inducted into the NAEPC Estate Planning Hall of Fame® in 2011. He was named one of the 24 “Elite Estate Planning Attorneys” and the “Top Estate Planning Attorney of 2018” by The Wealth Advisor and one of the Top 100 Attorneys in Worth.  He is listed in The Best Lawyers in America®, which also named him Las Vegas Trusts and Estates/Tax Law Lawyer of the Year in 2012, 2015, 2016, 2018, 2020, 2022, and 2024. He can be reached at 702-341-6000 or [email protected].  His law firm’s website is www.oshins.com.