Clients (ages 72 and 71 respectively) are the founders of a very successful business employing 700 people worth $54MM. Clients also have additional personal assets of $40M consisting of multiple residences, 2000 acres of pristine riverfront land and other investments. They have 5 adult children and 6 grandchildren.
Clients had an unfunded revocable living trust in place and $5MM second-to-die life insurance policy held in a defective Irrevocable Life Insurance Trust (ILIT). Their estate tax exposure under this plan was $40MM.
Our recommended strategies consisted of implementing a restated, fully funded, revocable living trust; a new ILIT holding a $10MM second-to-die policy using premium financing; formation of a family foundation; an Employee Stock Ownership Plan (ESOP); an employee scholarship program for deserving company employees and their children; a conservation easement on their riverfront acreage; a testamentary charitable lead annuity trust; and multiple irrevocable trusts to hold company stock for their children. We estimate their current estate tax exposure at $0.