The start of 2026 brings tax regime changes in several countries, notably including a revision of the U.S. federal estate and gift tax exemption threshold and an offshore capital amnesty in Mexico
Greater Exposure to the Estate Tax
As of January 1, 2026, the United States has raised the threshold for the federal estate and gift tax following the enactment of the so-called One Big Beautiful Bill Act (OBBB Act), which modified federal exemptions. In 2026, the unified exemption stands at $15 million per individual, up from $13.99 million in 2025.
This threshold represents the total value of lifetime gifts and estate transfers a person can make without triggering federal estate or gift tax. Any amount exceeding the exemption is generally subject to a federal tax rate of up to 40%.
In addition, several tax cuts introduced in 2025 under the OBBB Act have been made permanent. These include lower income tax brackets and expanded deductions, such as an increased child tax credit of $2,200, as well as temporary special deductions for seniors, tips, auto loan interest, and overtime pay.
According to a report by Insight Trust, “High-net-worth families in the U.S. should immediately review their estate and gifting structures, as a greater number of heirs may now fall under estate tax liability with the lower exemption threshold. Strategies such as using trusts before death, life insurance, or planning tax residency are increasingly important tools for minimizing tax exposure.”
Mexico’s 2026 Capital Repatriation Program
Mexico’s Voluntary Capital Repatriation Program, coming into effect in 2026, allows taxpayers to regularize legally sourced capital held abroad before September 2025, provided the funds are brought into or returned to Mexico during the 2026 fiscal year. Both individuals and legal entities residing in Mexico, as well as non-residents with a permanent establishment in the country, may participate.
The program’s main incentive is a preferential 15% income tax rate, applied to the full amount of repatriated capital. This tax is final—no deductions, credits, or offsets are allowed—and payment fulfills all tax obligations related to the repatriated funds.
A central condition of the program is that the returned capital must not remain idle. The regulation requires that the funds be invested in Mexico and remain invested for a minimum of three years. Eligible investments include productive assets, business projects, permitted acquisitions, or authorized financial instruments, all subject to criteria established by the tax authority (SAT). Taxpayers must formally declare how the funds will be used and file a specific notice, along with the appropriate tax return for each repatriation transaction.
The regime also includes post-compliance limitations. For example, if the repatriated funds are used to pay dividends or profits before meeting the minimum investment term, additional income tax may apply under general tax rules. Failure to comply with any requirement, such as meeting the deadlines, maintaining the investment, or submitting proper notices, could result in the loss of tax benefits and the imposition of additional tax liabilities by the authorities.
Mexico previously implemented a similar repatriation program between 2016 and 2017 under the administration of Enrique Peña Nieto. At that time, approximately 380 billion Mexican pesos were returned, according to data from the Ministry of Finance, generating an estimated income tax revenue of between 20 and 25 billion pesos. When converted to U.S. dollars using the exchange rate as of January 21, 2026, the repatriated capital amounts to roughly $21.6 billion, with related tax revenues between $1.1 billion and $1.4 billion.
