The UHNW 2025 Year-End Playbook: Which 7 Strategic Moves Should I Make Before December 31, 2025?
By Sean Hummel, CFP®
November 16, 2025
“The wealthiest families don’t chase tax breaks — they anticipate the terrain.”
The One Big Beautiful Bill Act (OBBBA) has reshaped the 2025 landscape in ways that quietly favor proactive households. Below are seven moves worth noting.
Move #1: The $77,500 After-Tax Window Remains Open
A rarely discussed 401(k) provision (IRS Notice 2024-2) continues to permit significant after-tax contributions followed by in-plan conversions.
For households with robust cash flow, this channel offers a way to shift capital into tax-free growth — provided employer plan documents allow it.
Move #2: State & Local Tax Dynamics Have Shifted
The new $40,000 federal ceiling on itemized state and local tax deductions often referred to as SALT pairs with pass-through entity tax elections in 36 states. An additional nine states have no income tax. The residents of the following states without this option. Delaware, Maine, North Dakota, Pennsylvania, Vermont)
High-property-tax jurisdictions (NY, CA, CT) now present a different arithmetic for operating companies and real estate holdings.
Move #3: Appreciated Securities Carry Hidden Leverage
When public equities with low cost basis are transferred to a donor-advised fund, the interplay of Section 170(b)(1)(A) and Section 170(e) can neutralize capital-gains exposure while preserving deduction capacity.
Timing matters: the benefit compounds when multiple years of giving are accelerated into a single tax year.
Move #4: Required Minimum Distributions Can Vanish Silently
For those 70.5 years of age or older, direct charitable transfers up to $108,000 satisfy RMD obligations without inflating adjusted gross income.
This tactic can influence not only income tax, but also Medicare premium thresholds and Social Security benefit taxation.
Move #5: Qualified Small Business Stock Rules Reward Patience
Section 1202 continues to exclude up to $10 million in gains per spouse, per qualifying C-corporation, provided the five-year holding clock is met.
Founders and early investors often discover multiple “stacks” across entities — a detail easily overlooked in concentrated portfolios.
Move #6: Bonus Depreciation Retains Front-Loaded Power
The 100% immediate expensing election applies to certain real estate improvements and syndicated investments placed in service after July, 19 2025. (Section 168(k)(8))
Material participation requirements remain the gating factor for offsetting ordinary income.
The OBBBA also introduces new Section 168(n), which allows a 100% deduction for “qualified production property”. This includes domestic real property used in manufacturing, refining, or agricultural production.
Move #7: Annual Exclusion Climbs to $19,000
Indexed inflation adjustments now permit $19,000 per donee without touching lifetime estate/gift exemption.
When combined with five-year 529 acceleration or direct payment of tuition/medical expenses, the leverage multiplies across generations.(Rev. Proc. 2024-40)
Closing Note
The most effective UHNW strategies rarely involve heroic moves.
They emerge from quiet alignment between legislative intent, family objectives, and mathematical reality.
If any of these moves resonates with you, we can see if you are in a position to take action.
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