We do not replace your attorney, CPA or trustee. We bring their disciplines together.

Our role is not to replace the client’s estate-planning attorney, CPA, tax counsel, investment adviser, trustee or insurance professional. We help bring those disciplines together so that sophisticated planning techniques are evaluated within the context of the family’s entire financial picture.

Effective planning does more than minimize one tax

High-net-worth estate planning requires an understanding of three closely related federal transfer-tax systems. A sound strategy also has to account for:

• Income-tax consequences
• Cost basis
• Liquidity
• Control of assets
• Creditor considerations
• Family objectives
• Asset appreciation
• State taxation
• Trust administration
• Investment management
• Real estate ownership
• Insurance
• Business succession

Advanced estate planning is a capital-allocation and governance exercise, not simply a document-drafting exercise.

Separating assets and appreciation from the personal estate

Irrevocable trusts can play an important role in sophisticated estate planning because, when properly structured, they may allow assets, appreciation, insurance proceeds or other economic interests to be separated from an individual’s personal estate. Depending on the client’s objectives and the advice of qualified legal and tax counsel, planning may involve structures such as these.

Spousal Lifetime Access TrustSLAT

Gift to irrevocable trust

One spouse transfers assets to an irrevocable trust established for the benefit of the other spouse and potentially additional beneficiaries. The structure can allow a family to move appreciating assets outside the donor’s taxable estate while retaining indirect economic access through the beneficiary spouse.

Considerations

• Gift-tax exemption utilization
• Trust design
• Beneficiary access
• Divorce or death of the beneficiary spouse
• Reciprocal trust doctrine
• Trustee selection
• Asset selection
• Investment strategy
• State trust law

Intentionally Defective Grantor TrustIDGT

Grantor trust rules

An IDGT separates the trust’s treatment for estate-tax purposes from its treatment for income-tax purposes. When properly designed, the grantor may remain responsible for certain income taxes generated by the trust even though the trust assets may be outside the grantor’s taxable estate.

That makes the IDGT particularly relevant for highly appreciating assets, closely held businesses, investment holdings and family wealth transfers.

Gift and sale transactions

An individual may make an initial contribution to the trust, then sell additional assets to the trust in exchange for a promissory note.

• Asset valuation
• Applicable federal rates
• Expected appreciation
• Cash flow
• Note repayment
• Trust liquidity
• Income-tax treatment
• Estate-tax exposure

The economics of the transaction matter as much as the legal structure.

Generation-Skipping & Dynasty TrustsGST

GST exemption allocation

For families thinking beyond children to grandchildren and future generations, GST planning becomes particularly important. A properly structured multigenerational trust may allow families to preserve assets for descendants.

Addresses

• GST tax exposure
• Asset protection
• Beneficiary distributions
• Trustee succession
• Family governance
• Investment management
• Real estate
• Family businesses
• Long-term stewardship

Where permitted under applicable state law, some families may consider long-duration or so-called dynasty trust structures intended to preserve family capital across multiple generations.

Grantor Retained Annuity TrustGRAT

Hurdle: §7520 rate

Commonly considered when an individual owns assets that may appreciate substantially. The grantor transfers assets to the GRAT and retains the right to receive annuity payments for a specified period.

If asset growth > statutory hurdle rate, part of the excess appreciation may pass to beneficiaries with reduced additional transfer-tax consequences.

Often used for

• Concentrated securities
• Closely held companies
• Pre-liquidity-event assets
• Rapidly appreciating investments
• Certain investment portfolios

Suitability depends heavily on valuation, investment performance, interest rates, mortality considerations and tax circumstances.

Qualified Personal Residence TrustQPRT

Retained occupancy term

For families whose residences represent a meaningful portion of the estate. An individual transfers a qualifying residence into an irrevocable trust while retaining the right to occupy it for a specified period.

Planning issues

• Property appreciation
• Retained occupancy
• Gift valuation
• Mortality risk
• Property expenses
• Post-term occupancy arrangements
• Real estate taxes
• Insurance
• Estate inclusion

Because real estate is often a substantial component of family wealth, QPRT analysis should be coordinated with the family’s broader real-estate and estate strategy.

Charitable Remainder TrustCRT

CRAT · CRUT

Combines charitable planning with an income interest for non-charitable beneficiaries. A donor contributes assets and receives, or designates others to receive, payments for a specified period. The remainder passes to one or more charitable organizations. CRTs are particularly relevant when evaluating appreciated assets.

Planning involves

• Charitable objectives
• Diversification
• Capital-gain considerations
• Income requirements
• Investment management
• Payout rates
• Remainder values
• Charitable deductions

Structured as a Charitable Remainder Annuity Trust (CRAT) or a Charitable Remainder Unitrust (CRUT), depending on the circumstances.

Charitable Lead TrustCLT

Philanthropy + legacy

A CLT reverses the payment structure of a CRT. The charitable organization receives the initial economic interest, and designated family beneficiaries may ultimately receive the remaining trust assets. It suits families who want to combine philanthropy with intergenerational wealth planning.

Effectiveness depends on interest rates, asset growth, trust duration, tax characteristics and the family’s charitable objectives.

Different economic interests in the same property can be separated

One party may receive an income interest. Another may receive the remainder. The grantor may retain an interest for a period, or a charity may receive one portion while family members eventually receive another. Understanding how those interests are valued and taxed is central to sophisticated transfer-tax planning.

Grantor or donor Family beneficiaries Charity

Lead / term interestRemainder interest

GRAT

GrantorAnnuity payments

FamilyExcess appreciation

QPRT

GrantorRight to occupy

FamilyThe residence

CRT

Donor / designeesPeriodic payments

CharityRemaining assets

CLT

CharityInitial payments

FamilyRemaining assets

The broader planning conversation

Depending on the family and its assets, planning may also include the following.

Substantial value, without corresponding liquidity

Real estate presents distinct estate-planning challenges. A family may own:

• Commercial real estate
• Apartment buildings
• Agricultural land
• Development property
• Vacation properties
• Family residences
• Triple-net leased investments
• Property held through LLCs or partnerships

Advanced planning should consider not only the value of the property, but also:

• Cash flow
• Debt
• Tax basis
• Appreciation
• Liquidity
• Entity structure
• Management
• Insurance
• Beneficiary interests
• Sale strategy
• Estate taxes

This is where our combination of fiduciary advisory and real-estate experience becomes particularly relevant.

Estate planning should not operate independently from wealth planning

We look across the client’s financial structure to identify where decisions intersect.

The objective is not simply to create sophisticated structures. It is to make sure those structures work together.

Six professionals, one financial structure

Designed for families and fiduciaries with complex balance sheets

• High-net-worth individuals
• Ultra-high-net-worth families
• Business owners
• Real-estate investors
• Executives
• Entrepreneurs
• Trustees
• Executors
• Family offices
• Families experiencing significant liquidity events
• Families preparing for intergenerational wealth transfers