General rule of thumb is 3" some not even that much. Dropping the t-case1" and rotating the rear diff up will gain you some more. This is what I had to do to run 5" in the back.
After 3" the steering and control arms needs to be addressed as well. Its been said that on an XJ the first 3" of lift cost $1000(if using a complete kit with all new springs, lines, bump stops, etc) and every 1" there after will cost $1000(trac bar,control arms, slip yoke eliminator(SYE), etc). This is if you buy all new parts and all the RECOMMENDED parts. It can be done cheaper.
Check out
www.naxja.org for more info.