Thank you so much for the reply, Kaye. The example that the IRS uses doesn’t quite apply directly to my suggested hypothetical. Because the IRS’s millionaire has gifted $9 million, which is MORE than the future BEA (thanks for that term too…”BEA”…new to me). My question applies to the millionaire who gifts less than the future BEA, but will have a unified prior gift and estate sum of more than the future BEA. My guy seems to get no credit for the prior gift yet had his gift been much bigger, he’d get full credit.
In the IRS scenario, above, the decedent will have been able to transfer $9 million tax free because he did so before 2026. Yet the millionaire who gifts $2 million today and dies with, say $10 million more after 2025, will only get credit for $5 million…right? Or will he/she get credit for $7 million, to be in fairness parity with the wealthier guy who was able to gift a full $9 million during his lifetime. (I know, taxation is often not fair, but I’m seriously just trying to understand how this is going to work.)