Estate · gift · charitable · fiduciary
Advanced Planning
Auditable simulators for the mainstream advanced-planning playbook. Every factor is computed from first principles using IRS Mortality Table 2010CM and the §7520 rate you supply — no opaque approximations. Outputs are CSV/PDF exportable for an audit binder.
What this is not: a tax-shelter or a substitute for a CPA / estate attorney. Every strategy here is a real Subchapter J / Chapter 14 planning technique published in the Code, regulations, or Tax Court precedent. Aggressive variants (sham trusts, tax protester arguments, abusive listed transactions) are explicitly excluded.
Advanced Planning — Pre-engagement disclosure
This tool produces ESTIMATES for educational and pre-engagement planning use only. Outputs do NOT constitute legal, tax, or investment advice and are not a 'covered opinion' under Treasury Circular 230. Engage a licensed estate-planning attorney and CPA before implementing any strategy modeled here.
Audit triggers / anti-abuse risks
- Reportable transactions (Reg. § 1.6011-4) — listed transactions, confidential transactions, transactions with contractual protection.
- § 7701(o) economic-substance doctrine: every transaction must have a non-tax business purpose AND meaningfully change the taxpayer's economic position.
- Step transaction doctrine: the IRS may collapse multi-step planning into a single taxable event if steps lack independent significance.
- Form 8275 / 8275-R disclosure required for positions contrary to regulations or with substantial-authority uncertainty.
Strategy simulators
Pay charity a fixed annuity, send remainder to heirs gift-tax-free. Solve for zero-out (Walton CLAT). Audit-grade Table B / S / U(2) math.
Mirror of CLAT — you take the income stream, charity gets remainder. Bypass cap gains on appreciated assets. CRUT/CRAT supported.
Rolling 2-year GRATs (Walton zero-out), Intentionally Defective Grantor Trust installment sale, Spousal Lifetime Access Trust modeling.
180-day reinvestment window. 10-year hold = basis step-up to FMV (no cap gains on QOF appreciation). Original gain recognized 12/31/2026.
Bundle 3–5 yrs of donations into one tax year to clear TCJA standard deduction; itemize that year, take standard the rest.
Asset deposit modules
Lack-of-marketability + minority-interest discounts on LLC/S-corp units. Wandry defined-value clause modeling.
Premiums via Crummey notices; death benefit outside the gross estate. 3-year lookback under § 2035.
Transfer property with debt. Bargain sale to charitable remainder + installment sale to grantor trust modeling.
3-year holding period for LTCG; vertical-slice planning to retain carried-interest character on transfer.
Distribution & fiduciary tools
Push trust income to lower-bracket beneficiaries via § 661/662 distributions. § 65-day election support.
Health/Education/Maintenance/Support standard checklist with audit log of trustee discretion. Required for ascertainable-standard trusts.
Lend at the IRS Applicable Federal Rate to preserve corpus. Avoids gift treatment under § 7872 if properly documented.
Move trust assets to a new trust with better terms. State-statute selector (UTC § 418, NY EPTL 10-6.6, etc.).
Build status
CLAT and CRT simulators are live with full audit-grade math. The remaining ten modules are scaffolded with tables, RLS, and citations in place — full simulator UIs are being built incrementally. Ask in chat to prioritize the next module.