Advanced Planning & Lifetime Wealth Transfer

Advanced Instruments

2026 minimum fees, before loadings

Each figure below is the minimum for the instrument, before the risk and timing loadings on this page, and the final fee for every engagement is fixed in a written engagement letter before work begins. Where an instrument is gift-driven, the fee includes a reporting memorandum for your return preparer covering adequate disclosure, gift-splitting posture, and GST exemption allocation. The firm coordinates that filing; it does not prepare gift tax returns.

Each minimum includes the first $7.5 million funded; each additional $1 million or part adds the stated per-million figure, and fundings above $50 million are individually quoted, with the computed figure shown as the indication.

All figures are minimums at the standard 90-day runway, before the loadings below. Each minimum includes the first $7.5 million funded; each additional $1 million or part thereof adds the per-million figure. Fundings above $50 million are individually quoted, with the computed figure shown as the indication. Computed fees round up to the nearest $500.

Companion Services

Below the floor by design

These services ride alongside the instruments: they keep exclusions alive, execute a confirmed architecture on new vintages, and capture the elections that preserve exemption. They are priced as companions, not as instruments, and annual administration never takes a loading.

The gifting exclusions we design around in 2026: $19,000 per recipient, $38,000 with gift-splitting, $194,000 to a non-citizen spouse. The Crummey notices are what keep the exclusion; skipping them is how ILITs fail on audit. A missed or misdated annuity payment is how GRATs fail. The portability filing preserves the deceased spouse's unused exclusion of up to $15,000,000.

Risk and Timing

The loadings: time and asset risk

The base fee prices the instrument. The funding prices the size: each $1 million or part above the included $7.5 million adds the per-million figure. The loadings price the engagement: how fast, and how hard to value. They compound, because a rushed transfer of hard-to-value wealth is riskier than the sum of its parts.

Where a day count and a calendar trigger both apply, the greater one governs; they never stack with each other. Engagements against a health deadline are accepted at the firm's discretion at the ×2 class or hourly. Expedite buys this firm's calendar only: appraisal lead times and IRS processing cannot be accelerated by fee.

Instruments combine. An entity, a grantor trust, a sale, and the executing 706 routinely price into six figures, and the largest engagements exceed $350,000. The engagement letter, not this page, fixes the number.

Time: the calendar decides. Size: the funding decides. Complexity: the asset decides. Above $50 million funded: the partners decide, by quote.

When a Flat Fee Is Not Appropriate

2026 hourly rates

Open-ended, contested, or high-volume matters, supporting organizations and other exempt structures, standalone buy-sell documents, and post-December-1 acceptances at the firm's election are billed hourly against a retainer.

Rates are rounded up to the nearest $5 and tier on the gross estate. Hourly rates vary depending on the scope of the matter, the subject matter involved, timing, availability, and other relevant factors. The current hourly schedule is maintained at bolandlawgroup.com/rates/.

Reading the Instruments

Different doors, all one-way

The names above are not a menu. Each instrument answers one question: who holds what, and when does it stop being yours. The funding then prices how large; the loadings price how fast and how hard to value.

ILIT

The trust owns the insurance so the death benefit lands outside both estates. Crummey withdrawal powers keep each premium gift inside the annual exclusion, and the notices that sustain them are administered annually; existing policies are screened for the transfer-for-value and three-year rules before they move.

SLAT

An irrevocable gift trust for the benefit of the other spouse: the wealth leaves both estates while the household keeps indirect access through the beneficiary spouse. Divorce and predecease contingencies are drafted, not assumed.

SLANT

The same access architecture drafted to non-grantor status, engineered around the grantor trust rules while the spouse remains a beneficiary, for clients whose planning turns on the income tax result as much as the transfer tax one.

SLATs, non-reciprocal pair

Two instruments deliberately differentiated in terms, timing, trustees, and assets, because courts uncross reciprocal trusts and the failure mode is inclusion in both estates. Priced as one design engagement, not two documents.

GRAT

A zeroed-out annuity trust designed against the month's 7520 rate: the annuity returns the value, appreciation above the hurdle passes at little or no gift tax cost, and the payments are administered to the day.

IDGT

A grantor trust by design: the grantor pays the trust's income tax, a burden the transfer tax does not count as a gift, and the trust is typically drafted GST-exempt and multi-generational in anticipation of a sale.

Installment sale to grantor trust

The transaction layer on the IDGT: a seed gift, then a sale for a promissory note at the applicable federal rate, with defined-value clauses and appraisal coordination carrying the valuation risk. The freeze moves everything above the note rate.

QPRT

The residence moves to the trust at a discount priced by the retained term. Outlive the term and the house is outside the estate, with a post-term lease-back at fair rent keeping you in it.

Standalone GST / dynasty trust

GST exemption allocated in life at a zero inclusion ratio, on trustee-succession architecture built for a horizon measured in generations. The exemption is not portable between spouses; allocation is how it is used rather than lost.

Family LLC / FLP

The container: transfer restrictions, management succession, and capitalization drafted so interests can be valued, gifted, and sold on your terms. The appraisal that prices each interest is third-party work, at cost.

Business succession

Succession designed across the entity, the trusts, and the gift or sale program together, so control and value transfer on different schedules when they should.

Charitable remainder trust

Income to your family first, remainder to charity, designed against the 10% remainder requirement, with flip and net-income variants for unmarketable assets.

Charitable lead trust

Charity leads, family remainders. A zeroed-out lead annuity trust can move the remainder at little or no transfer tax cost, and whether the trust is grantor or non-grantor decides who takes the deduction and who pays the income tax.

Private foundation

An institution rather than a trust: entity, bylaws, governance, self-dealing policies, and the federal exemption application, built to give in the family's name after the founder is gone.

BDIT / BDOT

A third party settles the trust; the beneficiary manages it, may sell to it, and stands outside it for estate tax purposes. Seed, guarantees, and audit posture are analyzed before a word is drafted.

Decanting, NJSA, or modification

When a funded irrevocable trust has the wrong terms, the Arizona Trust Code's tools move it onto better ones. Remedial work on an instrument that already holds the wealth is advanced work by definition.

Asset-protection structuring

Arizona has no domestic asset protection trust statute, so self-settled protection is structured through entities or a trust sited in another state, with situs counsel engaged directly or passed through at cost. Offshore structures are referred out.

Form 706

The return where the plan becomes elections: QTIP and reverse-QTIP, GST allocation and inclusion-ratio schedules, and Form 8971 basis reporting, due nine months after death with an automatic six-month filing extension.