Question: On July 1, 2021, Trung gifts $11.7 million in cash and a motorcycle worth $15,000 to his son Ngoc, which uses all of Trung's 2021 gift tax exemption plus his lifetime exemption/base exclusion amount. Trung pays no gift tax, but files IRS form 709 to report the gift. Effective January 1, 2026, the US Congress changes the amount of lifetime exemption / base exclusion that each individual may give away under the gift or estate tax to $3.5 million. Trung dies on March 5, 2026. Trung's gross estate at the time of his death is $800,000. The amount that Trung's estate must pay estate tax on is $9 million (($11.7 million + $800,000) - $3.5 million).