Four quarterly tax-strategy memos and one annual outlook per year. Restrained, technical, no marketing language. Distributed by mail to clients and a small list of qualified prospects on request.
Our 56-page annual outlook examining the lifetime estate-and-gift exemption sunset, the post-sunset legislative landscape, and the four most-leveraged moves available to households between $20M and $150M during 2026.
The 2017 lifetime exemption sunsets December 31, 2025 — cutting available exemption from approximately $13.6M per individual to roughly $7M (inflation-adjusted). For high-net-worth households, this is the largest single tax-policy event in a generation, and 2026 is the cleanup year.
Inside: the four moves we believe households should evaluate before year-end — ranked by leverage, complexity, and execution time — plus a chapter on what the post-sunset legislative landscape likely looks like through the 2028 election cycle.
Each quarterly memo runs roughly 18–28 pages, focuses on one tax-strategy theme, and arrives at clients on the first business day of the quarter.
The 2025 sunset has come and gone; for households that did not act, the exemption is materially smaller, but several mitigation paths remain. We walk through reciprocal SLAT post-mortems, IDGT installment-sale strategies for households that missed the window, and the GST tax-allocation question.
The most-cited memo we publish. Seventeen items spanning loss-harvesting, RMD/Roth conversion timing, charitable-transfer execution, gift-tax-return prep, and a brief section on the practical realities of moving deferred comp to a different state mid-year.
Drawn from 87 founder engagements aggregating $1.2B of qualified gain. The memo includes our internal qualification-opinion template, the documentation pack we deliver for IRS exam defense, and a discussion of stacking strategies with non-grantor trusts.
For multi-state households, state liability often dominates federal. The memo covers the day-counting practice, source-of-income tests by state, and the increasingly aggressive states (NY, CA, MA) that audit residency claims with depositions and credit-card subpoenas.
Drawn from our 52-household cross-border book. We cover the standing US treaties, the practical day-counting rules, the FBAR/FATCA reporting cascade, and Section 877A modeling for clients evaluating expatriation.
For households giving 6–12% of NLW per year, the vehicle question matters more than the recipient question. We walk through the lifecycle math on each vehicle and discuss the under-discussed qualified-appreciated-stock optimization.
Memos are distributed to active clients automatically. A small number of qualified prospects also receive the bound memos by mail. Send a request and we’ll evaluate your eligibility.
If you’d rather skip the reading and discuss your situation directly, request a one-hour strategy session. The first hour is free.
Request strategy session