For simplicity, let's say this year the lifetime gift exclusion amount is $12M
Some people say the amount will shrink to $6M in 2026.
Let's say you give 12M to a friend this year and use up the lifetime gift exclusion amount.
What happens in 2026 when the amount shrinks to 6M? Do you suddenly have to pay gift tax on $6M because that is how much you exceeded the lifetime gift exclusion by.
If you die before 2026, do you "lock in" the $12M amount?