Can you expand on what you mean by item #2 ?
Sure.
You probably know: the federal estate tax is (currently) 40% of however much your taxable estate exceeds the basic exclusion amount (BEA). The BEA is currently $12.92M per person; it'll be cut in half in 2026. It's assessed within 9 months after death.
A person's taxable estate is an IRS term, but it's roughly whatever your net worth is minus however much you transfer to a surviving spouse and/or charity.
"I might have an estate tax problem" - I'm 54 and while I might get hit by a bus tomorrow, I'll likely live at least into my 80's. My investments might tank, and Congress might change the law, but odds are that if I don't take actions to prevent it, my taxable estate will exceed the BEA when I die and that 40% tax on the excess will be due.
"Gifting earlier is more impactful" - I'm pretty sure this was what you wanted me to expand on. I was mainly referring to the idea that for purposes of the BEA, the gift value is as of the day of the transfer, but a gift gets the gift itself *plus all future appreciation* out of your estate. So if I gift $10K in stock to my kid now that would be worth $50K the day before I die, then I've only used up $10K of the exemption rather than $50K. (Not a tax thing, but the $10K now might be more impactful on my kid than $50K later.)
The BEA is adjusted annually for inflation, but my investments historically have grown much faster than inflation - usually approximately 10% vs. 3%. Getting that 7% excess growth out of my estate three decades earlier compounds into quite a bit of impact.
Said the opposite way, my Dad has a similar problem. We've started an annual gifting program for him (he's 87 with dementia and I have full POA and full support from him) but because we started too late the compounding could outpace the gifting. Not my Dad's numbers, but say someone with $8M today growing at 9%, that's $720K growth in one year, which far exceeds $17K times three kids, and even $17K times three kids plus nine grandkids.
There is also of course the notion of giving up to the $17K per year per person annually, which doesn't even eat into the BEA. There are other tricks and strategies as well, of course.
One does lose the step up, and I haven't done the math on it but just based on gut feel, avoiding that 40% estate tax seems more valuable. With some of my kids, they might not even sell the investments I gave them for a long time, so any loss of step up and/or capital gain is still deferred for a while.
My father and I both live in Idaho, which has no state estate or inheritance taxes.