Estate & Wealth Transfer Planning
Protect your estate. Transfer wealth on your terms.

The New Landscape — Permanent $15M Exemption

The One Big Beautiful Bill Act, signed July 4, 2025, permanently increased the federal estate and gift tax exemption to $15 million per individual — $30 million for married couples — beginning January 1, 2026, with annual inflation indexing and no sunset. The 40% estate tax rate on amounts above the exemption remains. The step-up in basis at death is fully preserved.

For families whose estates approach or will grow beyond these thresholds, the planning work is not optional — it is the difference between the wealth you built going to your heirs or going to the federal government. A $40 million estate with no planning pays $4 million in estate tax. With comprehensive planning implemented over time, that exposure can be dramatically reduced or eliminated.

SLATs — The Foundational Wealth Transfer Tool

A Spousal Lifetime Access Trust allows one spouse to gift assets to an irrevocable trust for the benefit of the other spouse and descendants. The assets leave the grantor's taxable estate immediately — along with all future appreciation. The beneficiary spouse can receive distributions for health, education, maintenance, and support, giving the couple indirect access to trust assets while they compound outside both estates.

Each spouse can create a SLAT for the other, effectively using both parties' lifetime exemptions while maintaining indirect access. The two trusts must be meaningfully different to avoid the reciprocal trust doctrine — different trustees, different terms, executed in different tax years where possible.

IDGTs — Transferring Business Value Without Income Tax

An Intentionally Defective Grantor Trust is outside the grantor's estate for estate tax purposes but owned by the grantor for income tax purposes. Business interests sold to an IDGT via an installment note are transferred without income tax recognition — the sale is ignored for income tax purposes because the grantor and the trust are treated as the same person under the grantor trust rules.

The grantor receives note payments over time at the applicable federal rate. All appreciation above that rate accumulates in the trust, outside the estate, free of further estate tax. The grantor also pays income tax on the trust's earnings each year — an ongoing additional tax-free gift to the trust that further depletes the taxable estate.

GRATs, Dynasty Trusts, and GST Planning

A Grantor Retained Annuity Trust transfers asset appreciation to beneficiaries with minimal gift tax cost. The grantor retains an annuity for a fixed term and, if the assets grow faster than the IRS hurdle rate, the excess passes to heirs free of gift or estate tax. GRATs work especially well for business interests and concentrated stock positions expected to appreciate significantly during the term.

A dynasty trust is designed to hold assets across multiple generations — free of estate tax, gift tax, and generation-skipping transfer tax throughout its term. With GST exemption allocation, substantial family wealth can be placed into a structure that compounds outside every future taxable estate indefinitely.

Family Limited Partnerships and Valuation Discounts

Real estate portfolios and business interests contributed to a family limited partnership can be transferred to heirs or trusts at discounted values for gift and estate tax purposes. Minority interests that lack marketability and control typically qualify for discounts of 20 to 35 percent, supported by a qualified independent appraisal.

A 30% discount on a $10 million FLP interest means $10 million of economic value uses only $7 million of lifetime exemption — extending the reach of the available exemption by 43%. The FLP must have genuine business purpose, formalities must be maintained, and all transfers must be properly documented and reported on Form 709.