Section 1014 (Basis of property acquired from a decedent) establishes the federal income tax basis of inherited property at the FAIR MARKET VALUE at the decedent's date of death - the "step-up" (or "step-down") in basis. This wipes out unrecognized capital gain or loss that accumulated during the decedent's lifetime. The provision applies REGARDLESS of whether estate tax was actually owed - estates below the $15,000,000 (2026) basic exclusion amount permanent under OBBBA still receive §1014 basis adjustment. §1014(a) provides the general rule: basis equals FMV on date of decedent's death OR (if elected) the alternate valuation date under §2032 (six months after death). §1014(b) defines property acquired from decedent broadly - bequests, devises, inheritance, property in revocable trusts, joint tenancy with right of survivorship, community property (both halves under §1014(b)(6)). §1014(c) provides the critical IRD exception - "Income in Respect of a Decedent" (IRDs) under §691 do NOT receive step-up. This includes traditional IRAs, 401(k)s, deferred compensation, unpaid wages, accrued interest, installment notes, Series EE/I bond accrued interest, and §453A installment sale gain. §1014(e) "BOOMERANG" rule denies step-up when appreciated property is gifted to decedent within 1 year of death and reacquired by donor or donor's spouse. §1014(f) and Reg §1.1014-10 (T.D. 9991, finalized September 17, 2024 and corrected March 19, 2026) impose the CONSISTENT BASIS reporting rule - heir's basis cannot exceed the value reported on the federal estate tax return (Form 706) for property that increased estate tax liability. Form 8971 required from estates filing Form 706 (estates >$15M for 2026 deaths), with Schedule A statements to beneficiaries identifying assets and reported values; due earlier of 30 days after Form 706 due date (with extensions) or 30 days after actual filing. §2032 ALTERNATE VALUATION DATE election - executor may value entire estate 6 months after death instead of date of death; election is all-or-nothing for entire estate; only available when it REDUCES BOTH total estate value AND estate tax owed. §2032A SPECIAL USE VALUATION - working farm or business real estate valued at actual use (vs highest-best use); 2026 maximum reduction $1,460,000 per Rev. Proc. 2025-32. Community property states - Reg §1.1014-1 - BOTH halves of community property step up at first death, even surviving spouse's half (Reg §1.1014-6). The OBBBA (P.L. 119-21, July 4, 2025) made the $15M estate exemption PERMANENT (replacing 2026 sunset to $5M base + inflation) - §1014 step-up framework preserved entirely without modification.
The rule: Basis of inherited property = FMV on decedent's date of death (or alternate valuation date 6 months later if §2032 elected). Applies regardless of estate tax exemption use.
Critical exclusions (IRD - no step-up): Traditional IRAs, 401(k)s, qualified retirement plans, annuities, deferred compensation, U.S. Savings Bond interest, installment notes - all under §1014(c) / §691.
OBBBA $15M permanent: 2026 basic exclusion $15,000,000 per individual; portability via DSUE preserved. §1014 step-up applies regardless of whether estate tax owed.
Community property double step-up: Both halves of community property step up at first spouse's death (Reg §1.1014-6) - major advantage over JTWROS in non-community states (only decedent's half steps up).
Consistent basis reporting: §1014(f) / Reg §1.1014-10 (T.D. 9991 final 2024, corrected 2026); Form 8971 with Schedule A from Form 706 estates. Heir basis cannot exceed estate-tax-reported value.
Step-down works too: If property has DECLINED below original basis, §1014 ALSO applies - basis steps DOWN to FMV. Cannot avoid step-down by inheriting depreciated property.
| Eligible (Gets Step-Up) | NOT Eligible (No Step-Up) |
|---|---|
| Real estate (residential, commercial, raw land) | Traditional IRA - IRD under §691 |
| Publicly traded stocks and bonds | 401(k), 403(b), other qualified retirement plans - IRD |
| Privately held business interests (partnership, S-corp stock, LLC interests) | Annuities (non-qualified deferred annuity gain) - IRD |
| Collectibles, artwork, jewelry | Deferred compensation, unpaid bonuses - IRD |
| Tangible personal property (vehicles, household items) | U.S. Savings Bond (Series EE/I) accrued interest - IRD |
| Cryptocurrency, digital assets | Installment notes (gain portion) - IRD under §453B(c) |
| Patents, copyrights (capital element) | Renewal commissions, royalty payments accrued before death |
| Foreign assets (subject to US tax rules) | §691 income items in general |
| Cash basis A/R for ordinary income - NO step-up; IRD treatment | Lottery / gambling winnings accrued before death |
| Pension benefits paid to estate or heir - NO step-up to extent pre-tax | Crop payments under §451 accrual rules |
| §1014(b) Category | Detail |
|---|---|
| §1014(b)(1) - Bequest, devise, inheritance | Property passing under will or intestate succession - clear step-up |
| §1014(b)(2) - Revocable trust (lifetime grantor) | Property in trust where grantor retained right to revoke - included in gross estate; step-up |
| §1014(b)(3) - General power of appointment trust | Where decedent had general power to designate beneficiaries - estate inclusion under §2041 |
| §1014(b)(4) - Property held jointly with right of survivorship | Joint tenancy / JTWROS - one-half step-up generally; 100% step-up if decedent's contributions established |
| §1014(b)(6) - Community property | BOTH halves step up at first death - massive advantage in CA, AZ, TX, WA, NV, NM, ID, LA, WI |
| §1014(b)(9) - Property included in gross estate | Catch-all - any property required to be included in decedent's gross estate per any Code provision; basis adjusted |
| §1014(b)(10) - QTIP property under §2056(b)(7) | QTIP marital trust property included in surviving spouse's estate at second death; basis adjusted at second death |
| Spousal lifetime access trust (SLAT) | Generally NOT in donor's estate; NO step-up at donor's death; trust carries over carryover basis |
| Irrevocable grantor trust (Rev. Rul. 2023-2) | If trust assets NOT in gross estate, NO §1014 step-up even though grantor for income tax purposes |
| Ownership Type | Step-Up Treatment |
|---|---|
| Joint Tenancy with Right of Survivorship (JTWROS) - married, non-community state | Generally one-half steps up at first death (§2040(b)); surviving spouse's half retains original basis |
| JTWROS - non-spouses | Step-up proportionate to decedent's contribution to acquisition cost (§2040(a)) |
| Tenancy by the Entirety (TBE) | Similar to JTWROS for spouses - one-half step-up |
| Tenancy in Common (TIC) | Step-up to decedent's specific fractional interest only |
| Community Property (CA, AZ, TX, WA, NV, NM, ID, LA, WI) | BOTH halves step up at first death (§1014(b)(6); Reg §1.1014-6) |
| Quasi-community property (CA only - acquired elsewhere, treated as community on death) | Both halves step up if decedent CA resident at death |
| Migration concern - JTWROS state to community state | Title held as JTWROS in community state - need to retitle to community property to capture double step-up benefit; PLR available for transitions |
| Property purchased separate but held in community state | Default presumption is community property; "transmutation" agreement may convert separate to community |
Facts: Sarah and Tom (married 30 years) own home worth $1,500,000 at first spouse's death. Originally purchased for $300,000.
Scenario A - JTWROS in non-community state (Florida):
At Sarah's death:
Sarah's half: steps up from $150,000 to $750,000
Tom's half: retains $150,000 basis
Tom's new basis after Sarah's death: $750,000 + $150,000 = $900,000
Tom sells home for $1,500,000
Gain: $1,500,000 - $900,000 = $600,000 (less $250,000 §121 single exclusion) = $350,000 taxable
Scenario B - Community property (California):
At Sarah's death:
Both halves step up to FMV
Tom's new basis: $1,500,000
Tom sells home for $1,500,000
Gain: $0 - no taxable gain
Tax difference: $350,000 federal long-term capital gain at 20% (high bracket) = $70,000 plus state tax. Pure benefit of community property treatment.
| §2032 Element | Detail |
|---|---|
| Authority | IRC §2032 - alternate valuation date |
| Election | Executor's election on Form 706; all-or-nothing for entire estate |
| Date | 6 months after date of death (specifically, date 6 months after decedent's death) |
| Properties sold during 6-month window | Valued at date of actual sale/distribution/disposition (not date of death and not alternate date) |
| Eligibility | Election only available if it REDUCES BOTH (a) total gross estate value AND (b) estate tax liability after credits |
| Practical use | Declining asset values - estates with marketable securities or business interests that have dropped post-death |
| Effect on basis | Basis = alternate valuation date FMV (or interim sale date) |
| Election timing | Made on Form 706; binding once made; cannot be revoked |
| Reg §20.2032-1 | Detailed regulations on alternate valuation |
| §2032A Element | Detail |
|---|---|
| Authority | IRC §2032A - special use valuation |
| Purpose | Allows farm/business real estate valued at "actual use" rather than "highest best use" |
| 2026 maximum reduction | $1,460,000 (Rev. Proc. 2025-32) |
| 50% test | At least 50% of estate's adjusted value must be qualified real or personal property |
| 25% real property test | At least 25% of adjusted gross estate must be qualified REAL property |
| Qualified use | Used for farming or in trade or business at decedent's death |
| Active participation by family | Decedent/family materially participated in operation for at least 5 of 8 years before death |
| 10-year holding requirement | Qualified heir must continue qualified use for 10 years post-death; cessation triggers recapture under §2032A(c) |
| Basis effect | Basis = special use valuation (lower than FMV); heir trades estate tax savings for income tax cost on eventual sale at FMV |
| OBBBA new §1062 farmland | Separate deferral provision for sale of qualified farmland to qualified farmer; may interact with §2032A in planning |
| Common IRD Asset | Treatment |
|---|---|
| Traditional IRA | NO step-up; pre-tax balance fully taxable to beneficiary on distribution; SECURE Act 10-year rule generally applies |
| 401(k), 403(b) | Same as traditional IRA; pre-tax balance fully taxable to beneficiary |
| Roth IRA | After-tax contributions - NO income tax to beneficiary regardless; SECURE Act 10-year rule applies for non-eligible designated beneficiaries; conceptually no IRD because no pre-tax basis to recover |
| Non-qualified deferred annuity | Gain portion (excess of value over investment) is IRD; principal portion (basis) tax-free |
| Series EE / I U.S. Savings Bonds | Accrued interest from purchase to death is IRD; beneficiary pays income tax on accrued interest when bonds mature/redeemed; alternative - estate may elect to report accrued interest on decedent's final return |
| Installment notes | Gain portion of installment sale obligation is IRD under §453B(c); no step-up; beneficiary recognizes gain ratably as payments received |
| Cash basis A/R | Accrued unpaid wages, fees, dividends declared but not paid - IRD; beneficiary recognizes when collected |
| Tax-deferred annuity | Pre-tax gains IRD; principal recovered tax-free |
| S-corp accumulated earnings | NOT IRD; S-corp stock generally fully steps up under §1014; AAA tracked separately |
| Royalty payments accrued before death | IRD; beneficiary reports as collected |
| Series EE bonds with election to defer interest | IRD; beneficiary reports accrued interest at redemption (or election to current-report) |
| §691(c) deduction | Beneficiary may deduct estate tax attributable to IRD against income recognized - PARTIAL relief from double taxation |
| Consistent Basis Element | Detail |
|---|---|
| Authority | §1014(f) and Reg §1.1014-10; final regs T.D. 9991 (September 17, 2024); corrections T.D. 10054 (March 19, 2026) |
| Rule | Heir's initial basis cannot EXCEED the value reported on Form 706 IF the property's inclusion increased estate tax liability |
| Form 8971 | Required from estate filing Form 706 - reports values to IRS; Schedule A to each beneficiary identifying assets received and reported value |
| Filing deadline | Earlier of 30 days after Form 706 due date (with extensions) OR 30 days after Form 706 actually filed |
| Heir reporting | Use Schedule A value as basis on eventual sale; deviation invites IRS challenge |
| Penalty for higher-than-reported basis claim | §6662(k) - 20% accuracy-related penalty for inconsistent estate basis reporting; 40% gross valuation misstatement penalty |
| Estate-level penalty | §6662 - 20% penalty for substantial valuation understatements (value reported 65% or less of actual) |
| Estates not required to file 706 (below $15M) | No Form 8971 required; heir establishes basis through appraisals and market data |
| Subsequent value adjustment | Audit-determined value substitutes - heir's basis adjusts accordingly |
| §1014(e) Boomerang Element | Detail |
|---|---|
| Authority | §1014(e) - enacted to prevent abuse |
| Rule | NO step-up if (a) appreciated property gifted to decedent within 1 year of death AND (b) property reacquired by donor (or donor's spouse) from decedent's estate |
| Purpose | Prevent donor from "laundering" appreciated property through dying donee to get fresh basis |
| Effect | Property retains donor's original basis (carryover) - no step-up at death |
| "Passes back" issue | Limited PLR guidance; trust structures often used to avoid §1014(e) by directing property to other beneficiaries |
| Multiple beneficiaries | If donor is one of several discretionary trust beneficiaries, §1014(e) may not apply (discretion creates uncertainty) |
| 1-year window strict | Gift on Day 365 = potentially excluded; gift on Day 366 (>1 year) = full step-up |
| Spouse trap | Reacquisition by donor's spouse also triggers §1014(e); both spouses considered together |
| OBBBA Estate Provision | §1014 Interaction |
|---|---|
| Authority | OBBBA P.L. 119-21 (July 4, 2025) - made $15M basic exclusion permanent |
| 2026 exclusion | $15,000,000 per individual (inflation-adjusted); $30,000,000 per married couple via portability |
| Sunset eliminated | Prior law: 2026 reversion to $5M base + inflation (approximately $7M); OBBBA removed sunset entirely |
| §1014 framework | UNCHANGED by OBBBA - step-up at death continues regardless of exemption use |
| Estates below $15M | NO Form 706 required (unless portability sought); §1014 step-up still applies based on date-of-death FMV |
| Estates above $15M | Form 706 required; Form 8971 / consistent basis reporting triggered |
| Form 706 for portability (DSUE) | Even sub-$15M estate may file Form 706 to claim DSUE for surviving spouse; election triggers consistent basis |
| Planning impact | Larger estates can use exemption + §1014 step-up; smaller estates rely primarily on §1014 (no gift-tax planning needed) |
| Trust Type | §1014 Treatment |
|---|---|
| Revocable living trust (grantor retains right to revoke) | Included in gross estate under §2038; §1014 step-up applies |
| Irrevocable grantor trust (e.g., IDGT, GRAT remainder, SLAT) | If NOT in gross estate - NO §1014 step-up (Rev. Rul. 2023-2) |
| Rev. Rul. 2023-2 holding | Grantor trust status for income tax does NOT trigger §1014 step-up at grantor's death if assets are outside the gross estate |
| QTIP marital trust | Surviving spouse's QTIP election causes inclusion in surviving spouse's gross estate at second death; §1014 step-up at second death only |
| Bypass / credit shelter trust | Funded at first death; assets NOT in surviving spouse's gross estate; NO second step-up at survivor's death |
| SLAT | Excluded from donor's estate; trust assets carryover basis from donor; NO step-up at donor's death; consider distribution before or post-death analysis |
| Toggle trust / power of substitution | Substitution of trust assets with grantor's high-basis assets pre-death captures step-up - common planning technique |
| Power of appointment trap | If decedent has general power of appointment over trust, §2041 inclusion triggers §1014 step-up |
| §1223(9) Element | Detail |
|---|---|
| Authority | IRC §1223(9) |
| Rule | Inherited property is AUTOMATICALLY treated as held more than 1 year - long-term capital gain treatment regardless of decedent's actual holding period or heir's holding period |
| Effect on rate | 0%, 15%, or 20% federal LTCG rates apply on eventual sale (depending on income brackets); maximum 25% for §1250 recapture; maximum 28% for collectibles |
| Sale immediately after death | Even sale the day after inheriting qualifies as long-term |
| 2026 LTCG brackets (Rev. Proc. 2025-32) | 0% up to $49,450 single / $98,900 MFJ; 15% up to $545,500 single / $613,700 MFJ; 20% above |
| NIIT impact | 3.8% additional under §1411 if MAGI above $200K single / $250K MFJ |
| State tax | State rates apply at ordinary rates in most states; CA, NY among highest |
| Cross-Border Issue | Treatment |
|---|---|
| US person inheriting foreign property | §1014 step-up applies based on FMV at death; foreign currency conversion at date of death exchange rate |
| Non-resident alien (NRA) decedent | Estate tax exemption only $60,000 for NRAs; §1014 still provides step-up for US-situs property |
| Covered expatriate decedent §877A / §2801 | Recipient subject to 40% transfer tax under §2801 (January 2025 final regs); separate from §1014 |
| Foreign trust IRD analog | Distributions from foreign trust to US beneficiary - throwback tax §665-668; no §1014 step-up for foreign trust corpus accumulated |
| Treaty positions | Some treaties may modify US estate tax exposure for NRAs; §1014 step-up generally not treaty-modified |
| Foreign-situs real estate | Step-up under §1014; gain calculated in USD using historical exchange rates for original basis vs death-date for step-up |
| Form 3520 reporting | Required if inheritance from NRA or foreign estate exceeds $100,000 - separate from §1014 |
| Asset Type | Valuation Method |
|---|---|
| Publicly traded stocks | Average of high and low trading prices on date of death; weekend death uses average of preceding and following trading days |
| Publicly traded bonds | Average high/low; consider accrued interest separately as IRD |
| Real estate | Formal appraisal by licensed appraiser - retrospective if death older; Zillow/AVMs insufficient |
| Closely-held business / partnership / S-corp | Valuation expert; consider DLOM (discount for lack of marketability) and minority interest discount; IRS scrutinizes aggressive discounts |
| Artwork, collectibles | Specialty appraiser; documentation of comparable sales |
| Cryptocurrency, digital assets | Volatile - document exchange snapshot at time of death; multiple exchanges may differ |
| Patents, copyrights, intangibles | Income approach (DCF); market approach (comparable transactions); cost approach |
| Household goods, personal property | Aggregate appraisal; significant items individually appraised |
| Life insurance | Face amount payable (less premium prepayments); held in ILIT excluded from estate |
| Date of death certificate | Definitive proof of death date; obtain multiple certified copies |
Traditional IRA, 401(k), other pre-tax retirement accounts are IRD - NO step-up. Beneficiary inherits pre-tax balance. Common error: treating inherited IRA as having stepped-up basis. Practitioner must distinguish IRD from non-IRD inheritance.
Property held as JTWROS in a community state may default to JTWROS treatment - only one half steps up. Should be retitled as community property to capture double step-up. Common after move from non-community state.
Even in non-community state, spouses may have community property purchased during community-state residency. Apply community property rules to those specific assets. Document title and acquisition state.
§2032 election only valid if BOTH gross estate reduced AND estate tax reduced. Election available only when both conditions met - cannot elect to reduce just one. Form 706 instructions detail eligibility.
SLAT excluded from donor's estate - NO §1014 step-up. Rev. Rul. 2023-2 confirms. Practitioners assuming grantor trust = step-up are wrong. Plan accordingly with substitution power if step-up desired.
Series EE/I bonds with accumulated interest - interest is IRD; principal stepped up. Practitioner often misses interest IRD treatment. Beneficiary should consider electing to report accrued interest currently to spread tax burden.
Installment note received in inheritance - principal (basis recovery portion) tax-free; gain portion is IRD. Beneficiary recognizes gain as payments received. Cannot step up the gain element.
Estate filing Form 706 must file Form 8971 within 30 days. Even portability-only Form 706 (sub-$15M) triggers Form 8971 requirement. Many estate attorneys/CPAs miss this filing.
Heir's basis cannot EXCEED Schedule A value from Form 8971. Claiming higher basis triggers §6662(k) 20% penalty. Use Schedule A value unless audit-adjusted value higher.
Pre-death gift back to elderly donor for fresh step-up only works if donee survives 1+ year. Gift within 1 year + reacquisition by donor = no step-up. Track gift dates carefully.
Irrevocable grantor trust with substitution power - grantor can substitute high-basis assets for low-basis trust assets pre-death, capturing step-up on substituted-in assets while leaving trust intact for tax purposes. Many estate plans include this power but never exercise it.
Joint bank account between non-spouse (e.g., parent + adult child) - step-up only to extent of decedent's contributions under §2040(a). Adult child who contributed nothing gets full step-up on parent's death. Document contributions.
§2032A special use valuation lowers estate tax BUT also lowers basis. If heir plans to sell soon at FMV, election may cost more in income tax than estate tax saved. Model carefully.
Foreign property inherited - basis is USD FMV at date of death converted at date-of-death exchange rate. Beneficiary's later sale uses sale-date exchange rate. Track separately from foreign tax credit computations.
Partnership interest inherited - underlying §751(a) hot assets (unrealized receivables, substantially appreciated inventory) treated as IRD; no step-up. §743(b) coordination with §1014 requires partnership-level §754 election to maximize step-up on cold assets.
Cryptocurrency price extremely volatile - document specific exchange and timestamp at moment of death. Treasury and IRS guidance evolving; conservative approach - use widely-quoted exchange (Coinbase, Kraken) close at moment of death.
QTIP property included in survivor's gross estate at second death gets second §1014 step-up. Bypass / credit shelter trust assets do NOT - they stepped up at first death only. Different trust structures = different second-death basis outcomes. Estate plans should consider whether survivor needs second step-up.
Primary authority: IRC §1014 (Basis of property acquired from a decedent). §1014(a) (general rule - FMV at date of death). §1014(a)(1) (FMV at death). §1014(a)(2) (alternate valuation date under §2032). §1014(a)(3) (special use valuation under §2032A). §1014(a)(4) (qualified conservation easement under §2031(c)). §1014(b) (property acquired from decedent definition). §1014(b)(1) (bequest, devise, inheritance). §1014(b)(2) (revocable trust). §1014(b)(3) (general power of appointment). §1014(b)(4) (joint property). §1014(b)(6) (community property - both halves step up at first death). §1014(b)(9) (catch-all - property included in gross estate). §1014(b)(10) (QTIP property at second death). §1014(c) (IRD exception - no step-up for §691 income). §1014(e) (boomerang rule - 1-year pre-death gift returned to donor). §1014(f) (consistent basis with estate tax return). §1.1014-1 (general regulations). §1.1014-2 (property acquired from decedent definition regs). §1.1014-6 (community property regs - both halves step up). §1.1014-10 (consistent basis reporting - T.D. 9991 final September 17, 2024; corrected by T.D. 10054 March 19, 2026). §691 (income in respect of a decedent). §691(c) (deduction for estate tax attributable to IRD). §453B(c) (installment notes as IRD). §2031 (gross estate definition). §2031(c) (qualified conservation easement exclusion). §2032 (alternate valuation date - 6 months after death; all-or-nothing election; eligibility - must reduce both gross estate and estate tax). §2032A (special use valuation - farm/business real estate; 2026 maximum reduction $1,460,000). §2032A(c) (recapture for cessation of qualified use). §2038 (revocable transfers - included in estate). §2040 (joint interests). §2040(a) (proportionate to contribution for non-spouses). §2040(b) (qualified joint interests - spouses, half-step-up). §2041 (powers of appointment - general power triggers inclusion). §2056(b)(7) (QTIP - qualified terminable interest property). §2801 (transfer tax on gifts from covered expatriates - 40% on recipient; January 2025 final regs). §1014(f) consistent basis reporting; §6662(k) - 20% accuracy penalty for inconsistent estate basis reporting. §1223(9) (inherited property automatic long-term holding). §1(h)(1)(D) (unrecaptured §1250 gain - max 25%). §1411 (NIIT - 3.8%). §751 (partnership hot assets). §751(a) (unrealized receivables and inventory - IRD treatment). §754 / §743(b) (partnership basis adjustment - coordination with §1014 step-up). §877A (covered expatriate mark-to-market). Reg §1.691-1 through §1.691-7 (IRD regulations). §20.2031-1 (gross estate valuation). §20.2032-1 (alternate valuation regulations). §20.2032A-3 (special use valuation regulations). Form 706 (United States Estate (and Generation-Skipping Transfer) Tax Return). Form 8971 (Information Regarding Beneficiaries Acquiring Property From a Decedent). Schedule A (Form 8971) (individual beneficiary basis information). Form 1041 (US Income Tax Return for Estates and Trusts). Revenue Ruling 2023-2 (irrevocable grantor trust assets NOT in gross estate - NO §1014 step-up despite grantor status). Revenue Procedure 2025-32 (2026 inflation adjustments - $15M estate exemption, $1.46M §2032A maximum reduction, 2026 LTCG brackets, $14,000 annual gift exclusion, etc.). Treasury Decision 9991 (September 17, 2024) - final consistent basis reporting regulations. Treasury Decision 10054 (March 19, 2026) - corrections to T.D. 9991. One Big Beautiful Bill Act P.L. 119-21 (July 4, 2025) - made $15M basic exclusion PERMANENT; §1014 step-up framework preserved entirely. Tax Cuts and Jobs Act P.L. 115-97 (2017) - originally doubled exemption with 2026 sunset (now removed by OBBBA).