The imbalance between generation transfer (GST) tax-exempt assets and GST tax-susceptible trusts continues to grow. The much larger estate and gift tax exemption and GST exemption amounts available to taxpayers since the passage of the Tax Cuts and Jobs Act of 2017 (TCJA) have not slowed the growth of overfunded trusts vulnerable to GST taxes. If the transfer tax provisions of the TCJA expire as planned on 1 January 2026, the number of large trusts vulnerable to GST is