The big three cover most of what sophisticated planning requires — but rarely all of it. These are the structures most often layered alongside them.
Beyond the Big Three
Several of these earn their place once the lifetime exemption has been fully used — a GRAT moves appreciation with little or no exemption, an ILIT creates the liquidity to pay whatever estate tax remains, and a sale to a grantor trust freezes value without a fresh gift. Others solve problems the big three do not touch at all.
A grantor retained annuity trust transfers appreciation above the IRS hurdle rate to your family using little or no exemption. Often the natural next step for a client who has already used their exemption and keeps generating wealth.
An irrevocable life insurance trust keeps policy proceeds out of your taxable estate and provides the liquidity your family needs to pay estate tax without selling the business or the real estate.
Selling an appreciating asset to a grantor trust for a promissory note freezes its value in your estate while the growth accrues to your family — with no gain recognized on the sale.
CRTs and CLATs pair philanthropy with a current deduction and deferred recognition of gain — useful where a concentrated low-basis position is about to be sold.
A qualified personal residence trust moves a home — or a second home — to the next generation at a discounted gift value while you continue to live in it for a term of years.
Consolidating family assets into a partnership or LLC supports valuation discounts for lack of control and marketability, and centralizes management across generations.
Properly allocated generation-skipping transfer tax exemption can keep a trust outside the estate tax system for many generations, in states that permit it.
Irrevocable trusts designed around the five-year look-back to preserve assets while protecting eligibility for long-term care benefits.
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Which structure fits depends on facts no article can guess at. A conversation costs nothing and usually settles the question quickly.
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