The 2026 federal exemption is $15M per person, $30M per married couple. Above that, the transfer tax is 40%. The planning question is not whether to use the exemption but which assets to move, when, and through which structure.
Estate planning is asset location across generations. The core move is always the same: transfer assets whose future growth you expect to be high, so the appreciation happens outside your taxable estate. The structures differ in how much exemption they consume, who pays income tax on the assets, and how much control you retain.
We work alongside your estate counsel. We do not draft documents; we model the outcomes, stress the assumptions, and coordinate the investment side so the structure actually does what the plan intended.
The main tools, in rough order of how much exemption they use per dollar transferred: grantor retained annuity trusts (GRATs) at nearly zero, installment sales to intentionally defective grantor trusts (IDGTs) at a fraction of the assets moved, spousal lifetime access trusts (SLATs) and completed-gift non-grantor trusts at full value, and charitable lead annuity trusts (CLATs) where philanthropy is part of the plan.
Transfer the upside of an appreciating asset at near-zero gift tax cost. The classic pre-liquidity estate freeze.
Read the overview →A separate taxpayer for income tax purposes. The building block behind QSBS stacking, state tax planning, and multi-generational compounding.
Read the overview →The GRAT's philanthropic sibling: charity receives the annuity for a term, and the remainder passes to heirs at a deep gift-tax discount.
Read the overview →Sell appreciated assets inside a tax-exempt trust, defer the gain across a payout stream, and take a deduction up front.
Read the overview →A first meeting covers your situation, the strategies that plausibly apply, and what we would need to review before recommending anything.
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