As we begin to plan for 2026, perhaps the first thing we need to look at will be the expected changes to the retirement plan contribution rules for 2026.

While the One Big Beautiful Bill Act (OB3) just expanded the IRC 199A deduction to more owners of closely held pass-through businesses, there are still some limitations to that qualified business income deduction (QBI) that are not readily apparent.

Many other provisions of the Tax Code were also changed by these inflation adjustments. You are encouraged to read the entire Revenue Procedure to learn how these other changes will affect income taxes in 2026.

The take-away from the recent 2026 Priority Guidance Plan is to not expect much guidance from the IRS in the gift, estate, and GST areas for the next 18 months. If questions remain on the interpretation of gift, estate or GST taxes, individuals, will be forced to request (and pay for) Private Letter Rulings.

In recent years the IRS, along with Congress, seems to be stepping up its challenges to the deductibility of claims filed against a decedent’s estate, with many more conditions and limitations on the amount of the deduction.

A resulting trust is a remedy when a trust fails, i.e., when there are no surviving beneficiaries or when the trust instrument does not dispose of the trust property on its termination. The remedy attempts to carry out the settlor’s intent in those narrow situations. If the intent cannot be determined, the remedy can result in a reversion of trust property to the settlor or the settlor’s estate. However, if the court can determine what the settlor ‘would have wanted, had the trust not failed’ then, as with the Kalbach Trust, the court will attempt to effectuate the settlor’s presumed intent without imposing a resulting trust.

Individuals often use a revocable trust to avoid probate on their death. Surprisingly, having a successor trustee is not enough if there is litigation in the Tax Court.

In limited situations, a merger of two trusts might be more effective than a decanting of one trust to another trust, or a trust modification under the Michigan Trust Code which involves the probate court’s approval.

The OB3 ‘tinkered’ with the IRC 199A qualified business income tax deduction, essentially expanding the number of pass-through business owners who can qualify to claim some, or all, of the income tax deduction. Sadly, OB3 did not simplify the cumbersome phase-in rules or make the deduction available to all service providers as was hoped.

Achieving Better Life Experience Accounts (ABLE Accounts ) were introduced in 2014 to enable disabled individuals who rely on public benefit programs for support to work, earn and save for their own future. The One Big Beautiful Bill, along with the recent ABLE Age Adjustment Act, both expand eligibility and increase contribution opportunities to ABLE accounts, which will hopefully provide more savings incentives for disabled individuals.