Senate Democrats could take aim at dynasty trusts, and they would be wise to do so as they search for revenue, considering the hundreds of billions of dollars that are at stake. The big money wouldn't necessarily materialize in the first 10 years — that’s the period of time used by Congress's scorekeepers when figuring out how much money tax changes will raise or lose. But that's no excuse for lawmakers to sit tight. And it's worth noting that there isn't a constitutional requirement to let pre-existing trusts off the hook.

Those with billions or even hundreds of millions may be willing to roll the dice with INGs or dynasty trusts in South Dakota or elsewhere, because they think the tax savings and ability to preserve their wealth for future generations outweigh potential impending changes. For those with fewer zeroes, going to such great lengths may just not be worth the hassle anymore.

Alexis Leondis is a Bloomberg Opinion columnist covering personal finance. Previously, she oversaw tax coverage for Bloomberg News.

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