The 2026 exemption sunset and a $94 million estate.
A retired physician and her husband had accumulated significant assets over four decades. Their advisors had not addressed the scheduled reduction in the federal estate tax exemption. Monolith restructured the exposure before the window closed.
Forty years of disciplined accumulation. An exemption about to be cut in half.
Dr. Eleanor Whitfield and her husband had spent four decades building a diversified asset base: a primary residence, three investment properties, a substantial equity portfolio, and a deferred compensation arrangement from her medical practice.
Their combined estate was valued at approximately $94 million. They had a revocable living trust, updated wills, and a financial advisor who managed their investment portfolio. Their estate attorney had reviewed the documents two years prior and found no immediate concerns.
The concern was not immediate. It was scheduled.
The exemption sunset was not in anyone's plan.
The Tax Cuts and Jobs Act of 2017 doubled the federal estate tax exemption to approximately $13.6 million per individual. That provision is scheduled to sunset at the end of 2025, reverting the exemption to approximately $7 million per individual, adjusted for inflation.
Under the current exemption, the Whitfield estate faced a projected tax liability of approximately $31 million. After the sunset, that figure would increase to approximately $48 million — a $17 million increase driven entirely by a change in law, not a change in their circumstances.
Their existing advisors were aware of the sunset in general terms but had not modeled its specific impact on the Whitfield estate or proposed a response. The family had approximately eighteen months before the window to act under the current exemption would close.
A $17 million increase in tax liability driven entirely by a change in law.
Accelerating the use of the current exemption before it expires.
Spousal Lifetime Access Trust (SLAT)
Dr. Whitfield established a SLAT for her husband's benefit, transferring $13.6 million in appreciated securities out of her taxable estate while preserving his access to trust distributions. Her husband established a reciprocal SLAT for her benefit, structured to avoid the reciprocal trust doctrine.
Qualified Personal Residence Trust (QPRT)
The primary residence was transferred to a QPRT, removing the property's current value from the taxable estate while allowing the couple to continue residing in the home for the trust term. The discounted present value of the remainder interest was applied against the remaining exemption.
Charitable Remainder Trust (CRT) for deferred compensation
The deferred compensation arrangement — which would have been fully taxable as ordinary income on distribution — was restructured through a CRT, converting the income stream into a tax-advantaged annuity while directing the remainder to a donor-advised fund aligned with the family's philanthropic priorities.
Investment property restructuring
The three investment properties were transferred to a Family Limited Partnership (FLP), establishing valuation discounts for minority interests and lack of marketability. The FLP interests were then gifted to the SLATs over a two-year period.
The exemption was used before it expired. The liability was restructured.
The restructuring reduced the projected estate tax liability from $31 million to approximately $4.2 million — a reduction of approximately 86%. The couple retained full use of their primary residence, continued to receive investment income from the trust structures, and maintained access to trust distributions through the SLAT arrangements.
The engagement was completed fourteen months before the scheduled exemption sunset, providing a margin of safety against any legislative acceleration of the timeline.
The family's existing financial advisor continues to manage the investment portfolio within the new trust structures. Their estate attorney updated all underlying documents to reflect the restructured ownership.
This case study is a composite narrative. Names, profession, and identifying details have been changed to protect client confidentiality. The financial structures and outcomes are representative of actual engagements. Past results do not guarantee future outcomes. The Clearview Group does not provide legal or tax advice. All strategies are implemented in coordination with qualified legal and tax counsel.