Advanced Tax Optimization Strategies
Legal frameworks for minimizing estate taxes and managing capital gains across generations.
The Estate Tax Cliff
In the US, the federal estate tax exemption is currently historically high (roughly $13.6M per individual in 2024), but it is scheduled to sunset at the end of 2025, cutting the exemption roughly in half. SFOs must deploy structuring tactics now.
Common Mitigation Vehicles
| Vehicle | Mechanism | Best Used For |
|---|---|---|
| GRAT | Passes appreciation above hurdle rate tax-free | Highly volatile/appreciating assets (Pre-IPO tech) |
| SLAT | Irrevocable trust for spouse | Locking in current high exemptions while retaining indirect access |
| CLAT | Pays charity first, remainder to heirs | Combining philanthropy with wealth transfer |
Common Mistakes
Triggering the reciprocal trust doctrine by setting up identical SLATs for a husband and wife. The IRS will collapse them. The trusts must have materially different terms and assets.
Take the Next Step
Model your specific requirements using our interactive operational and setup tools.
View SFO Tools