Estate Exemption ($15M / $30M OBBBA § 70106) · IRC § 1014 Step-Up vs. § 1015 Carryover Basis

Estate Tax, Trust & Step-Up in Basis Analyzer

Compare holding appreciated stock or real estate inside a Revocable Living Trust for a 100% tax-free IRC § 1014 Step-Up in Basis at death vs. Lifetime Gifting (IRC § 1015 carryover basis) and Irrevocable Grantor Trusts (SLATs / Rev. Rul. 2023-2) under the 2026 $15M Single / $30M Married Exemption and State Estate Tax cliffs.

Exemption Year
Visual Explainer · The $30M OBBBA Exemption Changed the Gifting Playbook

Why 99% of Affluent Families Should Hold Low-Basis Assets in a Revocable Trust for the § 1014 Step-Up

PROJECTED ESTATE AT YR 15 $15,431,046 Appreciated Asset: $6,429,602 2026 Exemption: $30,000,000 PATH B · LIFETIME GIFT (IRC § 1015) $2,045,498 Cap Gains Tax Heirs inherit $250k carryover basis & pay 33.1% LTCG PATH A · REVOCABLE TRUST (IRC § 1014) $0 Capital Gains · 100% Step-Up Basis resets to $6,429,602 FMV at death · Avoids probate NET TO HEIRS $15,431,046 +$2,045,498 saved via Step-Up
Calculating...
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1Estate & Asset Profile
Click any i to inspect the IRC § 1014 / § 2010 rule.
All assets combined (real estate, brokerage, business, retirement, life insurance).
Taxable stock, ETFs, or real estate
What you originally paid
Cumulative taxable gifts reported on prior IRS Form 709 returns.
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Year-15 Net Inheritance Comparison (After Estate & Capital Gains Taxes)

$30,000,000 Federal Exemption
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Side-by-Side Estate Tax, Capital Gains Tax & Inherited Basis Table

Transfer Strategy Inherited Cost Basis Federal Estate Tax State Estate Tax Heirs' Cap Gains Tax Net to Heirs
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Statutory Radar: Step-Up vs. Carryover, Rev. Rul. 2023-2 & State Cliffs

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Your Trust & Estate Action Playbook