Entity structures built for
real planning situations.
These packages represent common starting frameworks we implement for specific client profiles — the combination of entities, trusts, and structures that address the most pressing tax, estate, and asset protection needs for each situation. Every engagement is customized, but these provide a practical starting point for the conversation.
From sole practitioner to
multi-generational family office.
Each package reflects a distinct client profile and planning situation. The structures listed are the typical components — the specific implementation depends on asset base, income level, state law, and family circumstances.
-
EntityProfessional LLC or S CorpOperating entity for professional income — W-2 salary + distributions to minimize payroll taxes
-
PlanDefined Benefit / Cash Balance Plan$200K–$300K+ annual deduction tied to the operating entity
-
TrustRevocable Living TrustProbate avoidance, disability planning, basic asset management at death
-
EntityReal Estate LLC(s)Separate entities for each investment property — liability isolation and depreciation tracking
- →$200K–$300K+ annual income tax deduction through the defined benefit plan — the largest single lever available to a professional
- →S corp salary/distribution optimization reduces FICA/self-employment tax
- →Real estate LLC separates liability from personal assets
- →Revocable trust avoids probate and provides seamless disability management
- →Foundation for adding irrevocable trust structures as income and estate grow
-
EntityOperating LLC / S CorpMain business entity with optimal tax classification
-
TrustSLAT — Spousal Lifetime Access TrustUses $15M exemption to remove assets from estate while preserving spousal access
-
EntityFamily Limited PartnershipHolds investment assets at 20–35% discount for gifting purposes; asset protection vehicle
-
TrustILIT — Irrevocable Life Insurance TrustHolds life insurance outside the estate; estate liquidity vehicle
-
PlanDefined Benefit PlanMaximum annual deduction tied to operating entity
- →SLAT removes $5M–$15M from the taxable estate — and all future appreciation — permanently
- →FLP allows annual exclusion gifting of discounted interests to children — stretching the exemption
- →ILIT provides estate liquidity and life insurance outside the estate
- →Defined benefit plan generates $200K–$300K+ annual deduction
- →Platform for QSBS planning and pre-sale trust funding when exit timing becomes clear
-
CorpC Corporation (if QSBS eligible)Conversion to C corp starts the QSBS holding period for up to $15M federal capital gains exclusion
-
TrustIDGT — Pre-Sale Trust FundingBusiness interests sold to irrevocable trust via note — sale proceeds flow outside the estate
-
TrustDynasty TrustRemainder beneficiary for sale proceeds — multi-generational holding vehicle with GST exemption
-
CharityCRT — Charitable Remainder TrustFor owners with charitable intent — sell tax-free, generate income stream and immediate deduction
-
EntityFLP with Discounted Minority InterestsPre-sale gifting of business equity at 20–35% discounts before the sale crystallizes value
- →QSBS: up to $15M of capital gains excluded from federal income tax — the largest single exit benefit
- →IDGT pre-sale funding: sale proceeds flow into trust outside the estate — estate tax may be avoided on those assets under current law on those proceeds
- →CRT: full sale proceeds reinvested tax-free, lifetime income stream generated from higher invested base
- →FLP gifting before sale crystallizes value at discounted prices — children receive greater portion of appreciation
- →Dynasty trust ensures sale proceeds compound outside every future estate indefinitely
-
EntitySeries LLC or Multiple Property LLCsLiability isolation per property; unified management at the top-level holding company
-
EntityHolding Company LLCParent entity managing the property LLCs — centralized cash flow and management
-
EntityFamily Limited PartnershipConsolidates portfolio for estate planning, valuation discounts, and annual exclusion gifting
-
TrustRevocable Trust + Pourover WillProbate avoidance for multi-state properties; seamless transfer at death
-
TrustIDGT for Portfolio TransferTransfer appreciated portfolio to trust at current value — future appreciation outside estate
- →Cost segregation on every acquisition generates large first-year deductions — conducted in-house
- →REP election (if spouse qualifies) converts passive losses to offset all household income
- →FLP enables discounted gifting of portfolio interests to children or trusts
- →1031 exchange coordination defers gain on dispositions — basis step-up planning determines hold vs. sell
- →IDGT transfers future appreciation outside the estate without income tax recognition
-
DAFDonor-Advised FundContribute appreciated assets, avoid capital gains, deduct FMV, distribute to charities over time
-
CRTCharitable Remainder Trust (CRT)Sell appreciated asset tax-free, generate lifetime income stream, immediate deduction
-
ILITILIT — Wealth Replacement TrustLife insurance funded by CRT income stream — replaces wealth passing to charity for heirs
-
Found.Private Foundation (where appropriate)For clients with $5M+ charitable intent and desire for grant-making control and legacy
-
CLATCharitable Lead Annuity Trust (CLAT)Trust pays charity first; remainder transfers to heirs — potentially gift-tax-free if assets outperform hurdle
- →CRT: sell $2M appreciated asset tax-free; invest full $2M vs. $1.6M after tax — 25% larger income base
- →DAF: donate crypto or stock — zero capital gains, full FMV deduction, distribute to any qualified charity at any pace
- →Wealth replacement ILIT ensures heirs receive full equivalent of charitable assets through life insurance
- →CLAT transfers appreciation above the IRS hurdle rate to heirs with minimal gift tax
- →All structures reduce the taxable estate while generating current-year income tax deductions
-
TrustRevocable Living Trusts (both spouses)Probate avoidance, disability planning, marital deduction coordination
-
TrustSLAT × 2 (one per spouse)Both exemptions used — $30M sheltered from estate; indirect spousal access maintained
-
TrustDynasty Trust with GST ExemptionMulti-generational holding trust — wealth compounds outside every future estate indefinitely
-
EntityFamily Limited PartnershipInvestment assets consolidated; annual exclusion gifting of discounted interests to dynasty trust
-
ILITILIT — Survivorship PolicyEstate liquidity vehicle; death benefit provides cash to pay estate taxes without forced asset sales
-
EntityReal Estate LLCs / Management EntityProperty-level liability isolation; separate management fee entity for active income
- →Both $15M exemptions deployed via dual SLATs — $30M sheltered from estate, all future appreciation escapes
- →Dynasty trust compounds wealth outside every future estate for children, grandchildren, and beyond
- →FLP annual gifting systematically reduces taxable estate without using exemption
- →ILIT provides estate liquidity — avoids forced liquidation of illiquid assets to pay estate taxes
- →Unified compliance — one team managing 1040, 709, 1041, 1065, 5500 for all entities and trusts
-
TrustDigital Asset TrustRevocable or irrevocable trust with specific digital asset provisions — key management, custodian authority, access protocols
-
DAFDonor-Advised Fund (DAF)Contribute appreciated crypto — zero capital gains, full FMV charitable deduction, flexible grant timing
-
EntityInvestment LLC for Active TradingSeparates active crypto trading from passive long-term holdings for tax characterization purposes
-
TrustSLAT or IDGT for Large PositionsTransfer highly appreciated, long-held positions to irrevocable trust — appreciation escapes estate
- →Year-round tax-loss harvesting — no wash sale rule on crypto, positions reestablished immediately
- →DAF donation: $500K position, $10K basis → zero capital gains, $500K deduction → $119K tax savings
- →Step-up in basis at death can eliminate accumulated gain — hold-until-death planning for large positions
- →Estate plan specifically addresses private key access, hardware wallet location, and fiduciary authority
- →Form 1099-DA compliance readiness for 2026 reporting requirements
-
CorpC Corporation (QSBS vehicle)Qualifying C corp structure maintained for Section 1202 exclusion — up to $15M gain excluded at exit
-
TrustSLAT funded with Company Stock Pre-IPOTransfer pre-liquidity equity to irrevocable trust — future appreciation escapes estate
-
Election83(b) Election StrategyFile within 30 days of restricted stock grant — locks in low value, starts QSBS holding period
-
CRTCRT for Concentrated Post-Liquidity StockDiversify concentrated RSU or option position tax-free; generate income stream and deduction
-
LLCManagement LLC for Side IncomeAdvisory fees, board income, and speaking fees structured through LLC for QBI deduction and DB plan
- →QSBS: up to $15M of gain excluded from federal income tax — $3.57M of tax savings on a $15M exit at 23.8%
- →83(b) election on restricted stock: locks in income recognition at grant-date value — all appreciation taxed at capital gains rate
- →Pre-IPO SLAT funding: transfer equity before valuation crystallizes — all future appreciation outside estate
- →CRT for RSU concentration: tax-free diversification, income stream, immediate deduction
- →ISO exercise timing modeled against AMT — optimize exercise schedule year by year
Individual components that
bolt onto any package.
These structures are not package-specific. They can be added to any of the frameworks above when the client situation calls for them.
Dollar-for-dollar credit against tax liability for qualifying research activities. Requires contemporaneous documentation maintained throughout the year. Form 6765 filed with the business return.
Intangible drilling cost deductions of 65–80% of the investment in the year of drilling. For clients in the highest tax brackets with passive income to offset, a meaningful near-term deduction source.
Serial GRATs funded with concentrated stock or business interests — capturing appreciation in excess of the IRS hurdle rate and transferring it to heirs or trusts with no gift tax. Ideal alongside SLATs and IDGTs.
Transfer a primary or vacation residence to heirs at a discounted gift tax value — retaining the right to live in the property for a fixed term. Removes future appreciation from the estate at a reduced exemption cost.
Document investment intent, establish art-secured lending facility (40–50% LTV), and implement step-up or charitable donation strategy based on the collection's appreciation profile.
Establish an SBLOC against the investment portfolio for tax-free liquidity — 50–70% of portfolio value available at competitive rates without triggering capital gains on portfolio holdings.
Full 1031 exchange coordination — qualified intermediary engagement, 45-day identification, 180-day close tracking, and basis carryover documentation for every property in the chain.
Systematic $19,000/recipient annual exclusion gifting — gift tracking, 709 preparation, Crummey notice management for ILIT gifts, and FLP interest transfer documentation for each gift cycle.
Which package fits
your situation?
| Structure / Feature | 01 Practice | 02 Business Shield | 03 Pre-Exit | 04 Real Estate | 05 Charitable | 06 Family Office | 07 Crypto | 08 Founders |
|---|---|---|---|---|---|---|---|---|
| Defined Benefit Plan | ✓ | ✓ | ✓ | — | — | ✓ | — | — |
| SLAT(s) | — | ✓ | ✓ | — | — | ✓✓ | ✓ | ✓ |
| IDGT / Installment Sale | — | — | ✓ | ✓ | — | — | ✓ | — |
| Family Limited Partnership | — | ✓ | ✓ | ✓ | — | ✓ | — | — |
| Dynasty Trust + GST | — | — | ✓ | — | — | ✓ | — | — |
| ILIT / Life Insurance | — | ✓ | — | — | ✓ | ✓ | — | — |
| Charitable (CRT / DAF / CLAT) | — | — | ✓ | — | ✓✓ | — | ✓ | ✓ |
| C Corp / QSBS Planning | — | — | ✓ | — | — | — | ✓ | ✓ |
| Real Estate LLCs / Cost Seg | ✓ | — | — | ✓✓ | — | ✓ | — | — |
| Digital Asset Estate Planning | — | — | — | — | — | — | ✓✓ | — |
| Annual Exclusion Gifting | — | ✓ | ✓ | ✓ | — | ✓ | — | — |
| Full Compliance (all returns) | ✓ | ✓ | ✓ | ✓ | ✓ | ✓ | ✓ | ✓ |
Not sure which package
fits your situation?
Our private assessment identifies your planning priorities in about 4 minutes. Or start with a discovery conversation — we will walk through your current structure and identify the right starting point.