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High Net Worth · Dallas

The Estate Tax Reason to Own Permanent Life Insurance Mostly Disappeared

The 2026 exemption is $15 million per person and it no longer sunsets. That removed the reason most people were sold permanent coverage - and clarified the reasons that actually mattered.

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Dev Gaymes · Licensed Insurance Advisor
September 5, 2026 · 12 min read · Last reviewed September 2026 by Dev Gaymes
Before you read this.I am Dev Gaymes, a licensed insurance broker - not an attorney, a CPA, or an investment adviser. Everything below runs through trust drafting, tax treatment and business valuation, none of which I practice. This describes how coverage fits alongside that work so you know what to ask your attorney and CPA. It is not a recommendation to buy anything.

For roughly a decade, the pitch to affluent families was a countdown. The estate tax exemption was temporarily doubled and scheduled to fall by half at the end of 2025, so buy permanent coverage now while the window is open. That countdown ended, and not the way anyone planned for.

What actually happened

The One Big Beautiful Bill Act, signed July 4, 2025, did two things. It raised the federal estate and gift tax exemption to $15 million per person - $30 million for a married couple using portability - effective January 1, 2026. And it removed the sunset entirely.

20252026 onward
Exemption per person$13.99 million$15 million
Married couple$27.98 million$30 million
Scheduled to fall to ~$7M in 2026YesNo - sunset removed
Rate above the exemption40%40%, unchanged
Inflation indexingYesYes, resuming 2027
Texas state estate taxNoneNone

Figures reflect the OBBBA (P.L. 119-21) as of the review date. “Permanent” means no scheduled expiration, not that a future Congress could not change it. Confirm current figures with your CPA or attorney.

Fewer than 0.2% of estates owe any federal estate tax at this threshold. Combined with Texas having no state estate tax, the practical result for the overwhelming majority of Dallas households - including most families who would describe themselves as high net worth - is that federal estate tax is no longer the planning problem.

If you were sold permanent coverage on the sunset argument, that argument is gone. This is worth saying plainly, because I do not think many advisors are volunteering it. If the case for your policy was “the exemption is about to be cut in half,” the premise no longer holds. That does not automatically mean the policy was wrong - but it does mean the reasoning deserves a fresh look rather than an assumption that nothing changed.

The problem that did not go away

Here is what the estate tax debate always obscured. For most affluent Dallas families, the difficulty was never the tax bill. It was that the wealth is not in a form anyone can divide, spend or hold onto without selling something.

Look at what North Texas wealth actually consists of:

  • Closely held businesses. The operating company that generates the income and represents most of the balance sheet, with no market and no easy way to split it among three children.
  • Commercial and investment real estate. Buildings, land, partnership interests - valuable, income-producing, and impossible to liquidate quickly at a fair price.
  • Oil, gas and mineral interests. Common in Texas estates, frequently fractionalised across generations already, and genuinely difficult to value.
  • Ranch and agricultural land. Often held decades, worth a multiple of basis, and carrying family meaning that makes a sale the worst outcome for everyone.
  • An appreciated primary residence. In Highland Park, Preston Hollow or Bluffview, frequently worth several times what was paid for it.

None of that pays a bill. And an estate composed of it faces a set of problems that a $15 million exemption does absolutely nothing to solve.

The four problems that remain

1. Equalising among heirs who want different things. One child works in the business and wants to run it. Two do not and want their share in cash. Without liquidity, the only mechanisms are selling the business or making the working child buy out the others - which usually means loading the business with debt at the worst possible moment. Insurance funds the difference so the outcome is a decision rather than a forced sale.

2. Funding a buy-sell agreement - and this got harder in 2024. In Connelly v. United States, a unanimous Supreme Court held that life insurance proceeds a company receives to fund a redemption are a corporate asset counted at date-of-death value, and that the obligation to redeem does not offset it. That can inflate the value of the very shares being redeemed. Entity-purchase arrangements written before 2024 frequently need restructuring, and that is attorney and CPA work.

3. Keeping the asset the family actually wants to keep. The ranch, the building, the business. An estate with no cash sells whichever asset is easiest to sell, which is rarely the one the family would have chosen. Liquidity is what converts “we had to sell it” into “we decided to keep it.”

4. Carrying costs during administration. Property taxes, insurance, debt service, payroll and maintenance continue while an estate is being administered. That period can run months. Illiquid estates frequently sell something early simply to fund the interim.

The reframe
Estate liquidity was never really about the IRS. It is about whether your family has options at a moment when they will not be in a position to negotiate. A $15 million exemption removes a tax bill that most of these families were never going to owe. It does not put a dollar in the account, and it does not make a building or a mineral interest divisible among three children.

Where permanent coverage actually earns its place

Given all that, permanent insurance is worth considering in a narrower set of situations than it is usually sold into:

SituationWhy permanent rather than term
Equalising heirsThe need does not expire. A term policy that lapses at 70 fails at precisely the moment it was bought for.
Buy-sell fundingThe obligation persists as long as the business does.
Estate liquidityDeath is the trigger, and it has no deadline.
Special needs trust fundingA lifetime need for a beneficiary who may outlive you by decades. More here.
Charitable replacementReplacing to heirs what is given to charity, whenever that occurs.
Final expense and estate settlementModest amounts, guaranteed to be there.

General framework, not a recommendation. Which structure fits depends on your assets, your entity structure and your attorney's plan.

And where it usually does not: Income replacement while children are young, mortgage coverage, and covering a term business loan. Those needs end, and term does that job for a fraction of the premium. A permanent policy sold for a temporary need is the most common expensive mistake in this category.

Structures worth asking your attorney about

  • ILIT ownership. A policy owned by an irrevocable life insurance trust is generally outside your taxable estate. At a $15 million exemption this matters to fewer families than it used to - but for those genuinely above the threshold, or concerned a future Congress lowers it, the structure still does its job.
  • Survivorship (second-to-die) policies. Insuring two lives and paying at the second death, which is when estate liquidity is typically needed. Usually less expensive than two individual policies and often available where one spouse would be difficult to insure alone.
  • Cross-purchase rather than entity-redemption buy-sell structures, which Connelly made more attractive for many small companies.
  • Collateral assignment where a lender requires it on a commercial or SBA loan. How that works.
  • Premium financing - occasionally appropriate at scale, frequently oversold. If someone leads with this before understanding your balance sheet, be careful.
What I would want you to be sceptical of. Any presentation that leads with an illustration rather than a problem. Any structure you cannot explain back to your spouse in two sentences. Any recommendation to replace existing coverage without a written comparison of what you give up. And anyone still using the sunset argument in 2026 - either they have not updated their material, or they are hoping you have not.

What I would actually do first

  1. Inventory what is liquid. Not net worth - cash and marketable securities that could settle obligations within 90 days without a forced sale.
  2. Ask your attorney what the estate would owe and when. Not just tax; carrying costs, debt, and any buy-sell obligation.
  3. Have your buy-sell reviewed if it predates mid-2024. Connelly changed the analysis and a lot of agreements have not been touched since.
  4. Check what coverage already exists, what it costs, and whether it is still doing the job it was bought for.
  5. Only then price new coverage, against a number your attorney and CPA agree on rather than an illustration.
How I work on these cases
I am the insurance layer of a team, not the quarterback. On a file like this the attorney designs the structure, the CPA models the tax, and I tell you what the coverage costs, which carriers will underwrite it at that face amount, and whether what you already own still fits. Where the honest answer is that you do not need more coverage, I would rather say so - a large permanent policy sold into a situation that did not call for it is the kind of thing that damages a reputation for years.
Related: the full advanced markets guide for ILIT, buy-sell and Connelly detail, Preston Hollow and Park Cities for local context, and the planning sequence.

Frequently Asked Questions

Do I still need life insurance for estate taxes in 2026?

Most families do not. The federal estate and gift tax exemption is $15 million per person and $30 million for a married couple as of January 1, 2026, made permanent by the One Big Beautiful Bill Act, and Texas has no state estate tax. Fewer than 0.2% of estates owe any federal estate tax at that threshold. If the reason you were sold a permanent policy was an approaching sunset, that premise no longer holds and the policy deserves a fresh look.

What is the 2026 federal estate tax exemption?

$15 million per person, or $30 million for a married couple using portability, effective January 1, 2026. The One Big Beautiful Bill Act signed July 4, 2025 raised it from $13.99 million and removed the scheduled sunset that would have cut it to roughly $7 million. The rate above the exemption remains 40%, and the amount is indexed for inflation beginning in 2027. Permanent means no scheduled expiration, not that a future Congress could not change it.

If estate tax is not the issue, why would I still want permanent coverage?

Liquidity. Most affluent Dallas estates are concentrated in assets nobody can divide or spend - a closely held business, commercial real estate, mineral interests, ranch land, an appreciated home. That creates four problems a large exemption does not touch: equalising among heirs who want different things, funding a buy-sell obligation, keeping the asset the family actually wants to keep rather than selling whatever is easiest, and covering carrying costs during administration.

What is an ILIT and do I still need one?

An irrevocable life insurance trust owns a policy so the death benefit sits outside your taxable estate. At a $15 million per person exemption this matters to considerably fewer families than it did when the exemption was half that. For families genuinely above the threshold, or those concerned a future Congress lowers it, the structure still does its job. Whether it is worth the cost and complexity in your case is a question for your estate attorney, not for me.

What is a survivorship policy and when does it make sense?

A survivorship or second-to-die policy insures two lives and pays at the second death, which is typically when estate liquidity is actually needed. It is usually less expensive than two individual policies covering the same total amount, and it can sometimes be issued where one spouse would be difficult to insure on their own. It fits estate liquidity and heir equalisation; it does not fit income replacement, since it pays nothing at the first death.

How did the Connelly decision change buy-sell agreements?

In 2024 a unanimous Supreme Court held that life insurance proceeds a company receives to fund a share redemption count as a corporate asset at date-of-death value, and that the obligation to redeem the shares does not offset that value. The practical effect is that the insurance can inflate the value of the very shares being redeemed. Entity-purchase agreements written before mid-2024 frequently need restructuring, and cross-purchase arrangements became more attractive for many small companies. This is attorney and CPA work.

Should I replace a permanent policy I was sold before 2026?

Not without a written comparison, and not on my say-so. A policy bought under the old exemption rules may still be doing useful work - liquidity, equalisation and buy-sell needs did not change. What changed is the tax argument. The right step is a review of what the policy actually does, what it costs, and whether the need it was bought for still exists. Sometimes the answer is that it is fine. Replacement carries real costs including new contestability periods and surrender charges, and anyone recommending it without showing you those is not being straight with you.

What should I be sceptical of when someone pitches permanent coverage?

Any presentation that leads with an illustration rather than a problem. Any structure you cannot explain back to your spouse in two sentences. Any recommendation to replace existing coverage without a written comparison of what you give up. And anyone still using the estate tax sunset argument in 2026 - either their material is out of date or they are counting on yours being.

Dev Gaymes is a licensed insurance broker, not an attorney or a tax advisor. General education, not advice about your situation, and not an offer of insurance or a quote. Policy provisions, riders, exclusions and tax treatment vary by carrier, product and state and change over time; figures cited are published values as of the review date. All coverage is subject to carrier underwriting approval, and policy terms, benefits, exclusions and limitations are governed solely by the issued policy contract. Always answer every application question completely and truthfully.

Illiquid Estate and Not Sure What You Need?

Tell me roughly what the estate consists of and what your attorney has structured. I will tell you what the coverage would cost and which carriers write at that face amount - and if the honest answer is that you do not need more, I will say that too.