GST Exemption 2026
Current year
The 2026 GST Exemption is $15,000,000.
Effective 2026-01-01Source: Rev. Proc. 2025-32 (IRS)Verified 2026-08-29
Compared with 2025
| Item | 2025 | 2026 | Change |
|---|---|---|---|
| Lifetime GST exemption | $13,990,000 | $15,000,000 | +$1,010,000 (+7.2%) |
Who it applies to
Taxpayers who make generation-skipping transfers, including those subject to estate, gift, or generation-skipping transfer tax
What changed this year, and why
The lifetime generation-skipping transfer (GST) exemption amount for calendar year 2026 is $15,000,000.
Common questions
- What is the generation-skipping transfer (GST) exemption for 2026?
- The lifetime generation-skipping transfer (GST) exemption is $15,000,000 for calendar year 2026.
Every amount on this page is a published figure rather than yours. The GST exemption headroom takes the number you enter and works it out against them, showing which published figure it used.
Which transfers the GST tax reaches
A generation-skipping transfer occurs when someone gives property directly to a skip person - typically a grandchild or more remote descendant - and the recipient is two or more generations below the donor. For lifetime (inter vivos) transfers, this is called an inter vivos direct skip, and it is the only kind of GST that must be reported on Form 709. For the transfer to qualify as an inter vivos direct skip, it must satisfy all three conditions: it must be subject to the gift tax, it must be of an interest in property, and it must be made to a skip person. Transfers that do not have to be reported on Schedule A of Form 709, such as annual-exclusion gifts, educational or medical payments, and most transfers to a spouse, are not subject to the GST tax. The donor may apply the lifetime GST exemption of $15,000,000 to these transfers to reduce or eliminate the tax.
Transfers Subject to the GST Tax You must report on Form 709 the GST tax imposed on inter vivos direct skips. An inter vivos direct skip is a transfer made during the donor’s lifetime that is: • Subject to the gift tax, • Of an interest in property, and • Made to a skip person.
2025 Instructions for Form 709 (IRS)
The exemption allocates itself to direct skips unless you elect out
When a donor makes an inter vivos direct skip during lifetime, the IRS will automatically apply a portion of the donor's unused GST exemption to the transferred property. This automatic allocation happens by operation of law unless the donor takes affirmative steps to prevent it. To opt out of the automatic allocation, the donor must file Form 709 and attach a written statement that clearly describes the transaction and specifies the extent to which the automatic allocation should not apply. Simply reporting the direct skip on a timely filed Form 709 and paying any GST tax due on the transfer will also prevent the automatic allocation from taking effect. This rule gives donors flexibility but requires them to monitor their transfers carefully, since failing to elect out means the exemption of $15,000,000 will be consumed automatically, leaving less available for other planning purposes.
In the case of inter vivos direct skips, a portion of the donor’s unused exemption is automatically allocated to the transferred property unless the donor elects otherwise. To elect out of the automatic allocation of exemption, you must file Form 709 and attach a statement to it clearly describing the transaction and the extent to which the automatic allocation is not to apply.
2025 Instructions for Form 709 (IRS)
Allocating the exemption is a one-way decision
The donor can apply this exemption to inter vivos transfers (that is, transfers made during the donor's life) on Form 709. The executor can apply the exemption on Form 706 to transfers taking effect at death. An allocation is irrevocable. Once a donor or executor allocates any portion of the GST exemption to a particular transfer, that allocation cannot be undone or modified in a later year. This means the allocation decision is permanent: if you allocate too much exemption to one transfer, you cannot reclaim the excess for another transfer; if you allocate too little, you cannot go back and increase it later. The irrevocability rule applies regardless of whether the allocation was made on a timely filed return, on an amended return, or through a late allocation. Because the allocation cannot be reversed, donors should carefully consider which transfers receive exemption and how much, especially since the lifetime GST exemption of $15,000,000 is a finite resource that must be allocated strategically across all generation-skipping transfers during the donor's life and at death.
The donor can apply this exemption to inter vivos transfers (that is, transfers made during the donor’s life) on Form 709. The executor can apply the exemption on Form 706 to transfers taking effect at death. An allocation is irrevocable.
2025 Instructions for Form 709 (IRS)
Allocating to a transfer not reported on this return
When allocating GST exemption to transfers that are not reported on the current Form 709 - such as prior-year gifts, transfers made in earlier years, or late allocations - the donor must attach a written statement to the return. This statement must be titled "Notice of Allocation" and must include specific information for each trust or other transfer: clear identification of the trust (including its EIN if known), the year the original transfer was reported on Form 709 (if this is a late allocation), the value of the trust assets at the effective date of the allocation, the amount of GST exemption being allocated to each gift, and the inclusion ratio of the trust after the allocation. The total of all exemption allocations must be calculated and entered on line 6 of the return. This procedure allows donors to allocate exemption to transfers after the fact, which is important because the allocation of the lifetime GST exemption of $15,000,000 to a transfer permanently reduces the GST tax on that transfer. Without a proper Notice of Allocation, the IRS may not recognize the allocation, leaving the transfer exposed to GST tax.
Notice of Allocation. To allocate your exemption to such transfers, attach a statement to this Form 709 and entitle it “Notice of Allocation.” The notice must contain the following for each trust (or other transfer).
2025 Instructions for Form 709 (IRS)
How each figure was verified
Each number below was read from a stored copy of the document named beside it, and checked to occur word for word in the quoted sentence. The digest is of that stored text.
Rev. Proc. 2025-32 (IRS)
- Lifetime GST exemption
For calendar year 2026, the generation-skipping transfer exemption amount under § 2631(c) is equal to $15,000,000.
By year
Every published year
11 years on record, 2026 back to 2016. Each year links to its own page, its own document and its own verification date.