1. Federal Estate and Gift Tax
| Item | Current Figure | Notes |
|---|---|---|
| Estate/gift basic exclusion | $15,000,000 per person; $30,000,000 per couple (2026) | Permanent; indexed from 2027 (2025 base year). OBBBA §70106; IRC §2010(c)(3). |
| Top estate / gift / GST rate | 40% | IRC §§2001(c), 2502(a), 2602. |
| GST exemption | $15,000,000 per person | Not portable between spouses. IRC §2631(c). |
| Annual gift exclusion | $19,000 per donee (2026); $38,000 split-gift | IRC §2503(b). Direct tuition/medical payments unlimited (§2503(e)). |
| Non-citizen spouse annual exclusion | $194,000 (2026) | IRC §2523(i). |
| 529 five-year front-load | $95,000 per beneficiary; $190,000 per couple (2026) | IRC §529(c)(2)(B); pro-rata estate snap-back if donor dies in window. |
| §7520 rate and mid-term AFR | See the monthly strip at the top of this page | Changes monthly -- re-verify. |
| §6662 valuation-misstatement penalties | 20% substantial (value reported ≤65% of correct); 40% gross (≤40%) | Estate/gift valuations; underpayment must exceed $5,000. |
| §6695A appraiser penalty | Greater of $1,000 or 10% of attributable underpayment; capped at 125% of appraisal fee | Penalizes the appraiser personally, in parallel. |
2. New Jersey Inheritance Tax
| Class | Who | Rate |
|---|---|---|
| A | Spouse / civil-union / domestic partner, children and all lineal descendants, parents, stepchildren | Exempt |
| C | Siblings; sons- and daughters-in-law | $25,000 exempt, then 11% (next $1,075,000), 13% (next $300,000), 14% (next $300,000), 16% (over $1,700,000) |
| D | Nieces, nephews, cousins, friends, unmarried partners, caregivers, step-grandchildren | 15% on first $700,000; 16% above. No meaningful exemption. |
| E | Charities and exempt institutions | Exempt |
Life-insurance proceeds paid to a named individual beneficiary are exempt regardless of class (N.J.S.A. 54:34-4). Proceeds payable to the estate forfeit the exemption. Return (Form IT-R) and payment due eight months after death; late tax accrues 10% per annum interest from the eight-month mark; the lien runs fifteen years (N.J.S.A. 54:35-5).
3. New Jersey Gross Income Tax
| Item | Current Figure |
|---|---|
| Top rate | 10.75% over $1,000,000 (trusts use the single-filer schedule -- no compression) |
| Capital gains | No preference -- taxed as ordinary income |
| Charitable deduction | None against the GIT |
4. NJ Realty Transfer / Mansion Tax
| Item | Current Figure |
|---|---|
| Realty Transfer Fee | Graduated, seller-paid; tops out ≈1.21% marginal (N.J.S.A. 46:15-7, -7.1) |
| Mansion tax (Graduated Percent Fee, eff. 7/10/2025 -- seller-paid, cliff on entire price) | 1% ($1--2M) · 2% ($2,000,001--2.5M) · 2.5% ($2,500,001--3M) · 3% ($3,000,001--3.5M) · 3.5% (above $3.5M) |
| CITT | Controlling interests in entities owning Class 4A commercial property only -- never residential (N.J.S.A. 54:15C-1) |
5. BAIT (Business Alternative Income Tax)
| Distributive Proceeds | Rate |
|---|---|
| First $250,000 | 5.675% |
| $250,001 -- $1,000,000 | 6.52% |
| Over $1,000,000 | 10.9% |
Annual entity-level election; cannot be made retroactively (N.J.S.A. 54A:12-3). Trusts and estates qualify as members; the refundable credit may be allocated to beneficiaries (N.J.S.A. 54A:12-5(b)).
6. Federal Income Tax -- Charitable
| Item | Current Figure |
|---|---|
| Itemizer charitable floor (eff. 2026) | Aggregate contributions deductible only above 0.5% of AGI; five-year carryforward of floor-disallowed amounts (IRC §170(b)(1)(I)) |
| Top-bracket deduction limit | 2/37 reduction -- caps benefit at ≈35¢ per dollar for 37%-bracket income (IRC §68) |
| Cash to public charity / DAF | 60% of AGI; 5-year carryforward |
| Appreciated property to public charity / DAF | FMV up to 30% of AGI; 5-year carryforward |
| Private foundation | Cash 30% of AGI; appreciated property at basis (publicly traded stock at FMV up to 20%) |
| Foundation excise tax | 1.39% of net investment income (IRC §4940(a)) |
| Foundation minimum distribution | 5% of net investment assets annually (IRC §4942) |
7. Federal Retirement / SECURE
| Item | Current Figure |
|---|---|
| Ten-year rule | Most non-EDB beneficiaries must empty inherited IRAs within 10 years |
| EDB exceptions | Surviving spouse; minor child (until majority); disabled/chronically ill; beneficiary ≤10 years younger |
| RMD age | 73 (born 1951--1959); 75 (born 1960+) |
| QCD age floor / annual limit | 70½ / $111,000 per individual (2026, indexed) |
| One-time QCD to CRT/CGA | $55,000 (2026, indexed); once per lifetime |
| Federal trust-bracket compression | Top 37% bracket at ≈$16,000 of retained trust income (2026) |
Medicare IRMAA thresholds
| Item | Where to Find the Current Figure |
|---|---|
| Medicare IRMAA (Parts B and D income-related surcharges) | Indexed MAGI thresholds, two-year lookback -- see the current SSA/CMS table. Band-specific dollar thresholds reset annually and are not reproduced here; read them from the SSA table for the year in question. |
8. QSBS (Section 1202)
| Item | Stock issued ≤ 7/4/2025 | Stock issued ≥ 7/5/2025 |
|---|---|---|
| Exclusion cap | Greater of $10M or 10× basis | Greater of $15M (indexed from 2027) or 10× basis |
| Gross-assets test | $50M | $75M (indexed from 2027) |
| Holding period | 5-year cliff | 50% / 75% / 100% at 3 / 4 / 5 years |
New Jersey conforms: P.L. 2025, c.67 -- gains excluded federally are excluded for NJ GIT purposes for tax years beginning on or after January 1, 2026, including pre-2026 stock disposed of in 2026 or later.
9. Professional Corporation / Buy-Sell
N.J.S.A. 14A:17-13(c): mandatory redemption within 375 days of a shareholder’s death; book value default if the buy-sell is silent on price.
10. Probate / Administration
Surrogate fees roughly $100--$200 for a typical will probate -- flat, page-based, never a percentage (N.J.S.A. 22A:2-30). No will may be admitted to probate before the tenth day after death (N.J.S.A. 3B:3-22).
11. Sources
Numbered sources transcribed verbatim from Appendix B of the manuscript (verified June 2026). Links go to official or stable landing pages; two convenience links to the IRS AFR index page are page additions, noted inline.
- OBBBA §70106, Pub. L. 119-21 (signed July 4, 2025), amending IRC §2010(c)(3); IRS Rev. Proc. 2025-32, §3.13 (basic exclusion amount $15,000,000 for 2026, indexed from 2027). See also IRS estate-and-gift “What’s New” guidance confirming permanence and 2025 base year.
- IRC §2001(c) (estate tax rate); IRC §2502(a) (gift tax rate); IRC §2602 (GST tax rate).
- IRC §2631(c) (GST exemption amount equal to basic exclusion amount). Portability is available for estate/gift tax under IRC §2010(c)(2) but does not extend to GST.
- IRC §2503(b); IRS Rev. Proc. 2025-32, §4.03 (annual exclusion $19,000 for 2026).
- IRC §2523(i); IRS Rev. Proc. 2025-32, §4.03 (non-citizen spouse annual exclusion $194,000 for 2026).
- IRC §7520. June 2026 §7520 rate 5.00%, Rev. Rul. 2026-11, 2026-24 I.R.B. 1570. The §7520 rate is 120% of the mid-term AFR under IRC §7520(a). Re-verify monthly -- the rate and ruling number change every month. (Convenience link added by this page, not a manuscript citation.)
- IRC §1274(d). June 2026 mid-term AFR 4.13% (annual compounding), Rev. Rul. 2026-11, 2026-24 I.R.B. 1570. Re-verify monthly -- the AFR changes every month with the same ruling that publishes the §7520 rate. (Convenience link added by this page, not a manuscript citation.)
- IRC §6662(g) (substantial estate/gift valuation understatement: 65% threshold, 20% penalty); IRC §6662(h) (gross valuation misstatement: 40% penalty, 40% threshold for estate/gift).
- N.J.S.A. 54:34-1 (imposition); N.J.S.A. 54:34-2 (classes and rates); N.J.S.A. 54:34-4 (exemptions).
- N.J.S.A. 54:34-2 (Class A definitions, including civil-union and domestic-partner amendments).
- N.J.S.A. 54:34-2 (Class C schedule).
- N.J.S.A. 54:34-2 (Class D schedule).
- N.J.S.A. 54:34-2 (Class E).
- N.J.S.A. 54:34-4 (life insurance exemption).
- N.J.S.A. 54A:2-1 et seq. (Gross Income Tax rate schedule); NJ Division of Taxation, GIT-1040 instructions confirming 10.75% top marginal rate for single filers over $1,000,000.
- NJ Division of Taxation guidance: New Jersey taxes capital gains as ordinary income with no preferential rate.
- New Jersey Gross Income Tax Act, N.J.S.A. 54A:3-1 et seq.; no charitable deduction is provided in the statute. See NJ-1040 instructions and Division guidance.
- N.J.S.A. 46:15-7, 46:15-7.1 (RTF schedule). NJ Division of Taxation, Realty Transfer Fee FAQs confirming graduated seller-paid schedule topping out at roughly 1.21% marginal rate for high-value residential transfers.
- P.L. 2025, c.69 (A5804/S4666), signed June 30, 2025, effective July 10, 2025, amending N.J.S.A. 46:15-7 et seq. to create the Graduated Percent Fee. EY Tax Alert and NJ Realtors confirm cliff-structure tiers and seller-pay shift. Also: https://www.njrealtor.com/government-affairs/realty-transfer-fee/
- N.J.S.A. 54:15C-1 (CITT limited to controlling-interest transfers of entities owning Class 4A commercial property). P.L. 2025, c.69 preserved commercial rate parity; no extension to residential entity transfers.
- N.J.S.A. 54A:12-3 (BAIT election and rate schedule). Monaco CPA confirms three-bracket schedule and non-retroactivity.
- P.L. 2021, c.419 collapsed the pre-2022 9.12% bracket on $1M--$5M into the top bracket, effective Jan. 1, 2022.
- N.J.S.A. 54A:12-5(b) (credit allocation for trust/estate members).
- OBBBA §70425(a)(1), adding IRC §170(b)(1)(I) (0.5%-of-contribution-base floor on the aggregate of an itemizer’s charitable contributions, all forms of property, effective tax years beginning after 12/31/2025; five-year carryforward for floor-disallowed amounts). See, e.g., Greenberg Traurig, “New Limitations on Charitable Deductions Take Effect in 2026” (Oct. 2025); Taft Law, “Charitable Giving After the OBBBA: The 2026 Outlook” (https://www.taftlaw.com/news-events/law-bulletins/charitable-giving-after-the-obbba-the-2026-outlook/).
- OBBBA §70111, rewriting IRC §68. CPA Journal and HIVE Tax AI confirm the 2/37 reduction applies to taxpayers with taxable income in the 37% bracket, effectively capping deduction value at 35%. Also: https://hivetax.ai/how-are-high-income-taxpayers-affected-by-itemized-deduction-caps/
- IRC §170(b)(1)(A) (60% AGI limit for cash to public charities).
- IRC §170(b)(1)(C) (30% AGI limit for long-term appreciated property to public charities).
- IRC §170(b)(1)(B) (30% AGI limit for cash to private foundations); IRC §170(b)(1)(C) and §170(e) (basis-only deduction for appreciated property to private foundations, except publicly traded stock).
- IRC §4940(a); Form 990-PF instructions confirm 1.39% rate for domestic exempt private foundations. Also: https://unclekam.com/tax-strategy-blog/excise-tax-on-private-foundations-2026-guide/
- IRC §4942 (minimum distribution requirement); Uncle Kam Tax Strategy Blog and Form 990-PF instructions confirm 5% of net investment assets, with 30% penalty on shortfall.
- IRC §401(a)(9)(H), as amended by the SECURE Act of 2019 (ten-year rule for most non-EDBs).
- IRC §401(a)(9)(E) (EDB categories).
- SECURE 2.0 Act §107 (RMD age 73 for those born 1951--1959); §305 (RMD age 75 for those born 1960+).
- IRC §408(d)(8)(B)(ii) (QCD age floor remains 70½ despite SECURE Act RMD age increases).
- IRC §408(d)(8)(A) (QCD annual limit indexed for inflation). Northern Trust Institute and William Blair confirm 2026 QCD limit is $111,000 (up from $108,000 in 2025). Also: https://www.williamblair.com/-/media/downloads/pwm/2026/williamblair_qualified-charitable-distribution.pdf
- SECURE 2.0 Act §307 (one-time QCD to CRT/CGA, limit indexed; $55,000 for 2026). Northern Trust Institute confirms $54,000 for 2025, rising to $55,000 for 2026.
- IRC §1202(a), (b), (c) (pre-OBBBA QSBS rules: $10M/10× cap, $50M assets test, 5-year cliff for 100% exclusion on post-9/27/2010 stock).
- OBBBA amendments to IRC §1202 (post-July 4, 2025 stock: $15M/10× cap, $75M assets test, tiered 50%/75%/100% at 3/4/5 years, indexed from 2027). Affairs of State, Brooklyn Fi, and Andersen confirm the tiered structure and higher thresholds. Also: https://www.brooklynfi.com/blog/how-to-prepare-for-an-ipo-2026 ; https://andersen.com/featured-insights/qsbs
- P.L. 2025, c.67 (A4455/S4503), signed June 30, 2025. Kulzer DiPadova and Mintz confirm NJ GIT conformity to §1202 effective for tax years beginning on or after January 1, 2026. Also: https://www.mintz.com/insights-center/viewpoints/2906/2025-07-14-new-jersey-adopts-qsbs-exclusion-game-changer-state
- N.J.S.A. 14A:17-13(c) (375-day redemption period; book-value default absent agreement).
- N.J.S.A. 22A:2-30 (surrogate fees).
- N.J.S.A. 3B:3-22 (ten-day wait before probate admission).
Archive of Superseded Figures
Permanent snapshot of this edition: Figures as verified 2026-06.
No superseded figures yet -- this is the first published edition of this page (June 2026). When a figure changes, the prior figure moves here with its effective dates, so a reader holding an older printing can reconstruct what the book said and what has changed since.
This page is not legal advice. It is general information published as a companion to After You: Wealth, Family, and the Long Game for New Jersey’s Quietly Rich. Reading the book or this page does not create an attorney-client relationship with the author, with Britt J. Simon, or with Simon Law Group, LLC. The law changes; the figures above are verified only as of the date in the banner. Before acting on any figure or strategy, retain New Jersey counsel and verify the current number against the primary source. ATTORNEY ADVERTISING. Paid for by Simon Law Group, LLC, Somerville, New Jersey.