Trusts are among the most versatile tools available to address that complexity, but the right structure depends on what your client is trying to accomplish.
For a legal and trust professional like yourself, structure is only part of the equation. A trust also needs to be administered with confidence, which means beneficiaries must be properly identified, family relationships documented, and distributions supported by clear, court-ready documentation.
In 2026, the federal lifetime exclusion is $15 million per individual, with annual gift exclusions of $19,000 per recipient. For high-net-worth clients with significant appreciating assets, this creates planning opportunities. It also makes this a timely moment to review whether existing estate plans and trust structures still align with the client’s goals.
Start With the Client’s Goal, and Plan From There
Before any specific structure enters the conversation, the planning goal needs to be clear.
Is the client trying to maintain control during life? Reduce estate tax exposure? Transfer appreciation to the next generation? Provide for a surviving spouse? Protect assets from future creditors? Support charitable causes? Simplify administration after death? All of the above?
Those answers should guide the chosen structure. For example, a client focused on privacy and continuity may need a different solution than one focused on multigenerational tax planning or charitable legacy.
For fiduciaries and counsel, it is also worth considering how complex the beneficiary structure may become once the trust is administered.
Revocable and Irrevocable Trusts: Foundational Structures
Most high-net-worth trust conversations begin with the distinction between revocable and irrevocable trusts.
The primary advantages of a revocable trust are practical: they can help avoid probate, preserve privacy, support continuity of asset management if the grantor becomes incapacitated, and simplify administration when assets are held in multiple jurisdictions.
Even when a revocable trust simplifies administration, trustees may still need to confirm beneficiaries, identify successor interests, or resolve gaps in family documentation after death.
With an irrevocable trust, the grantor generally relinquishes control of the assets contained in the trust. In exchange, those assets may support tax planning, asset protection, or long-term wealth transfer goals. The trade-off is permanence. Irrevocable trusts are harder to modify after the fact, which makes careful design and documentation especially important.
For high-net-worth clients, many advanced planning strategies are built within the irrevocable trust category.
Advanced Structures for Tax, Growth, and Family Planning
Several irrevocable trust structures are worth considering when clients want to transfer appreciating assets, reduce estate exposure, or support family members over time.
Grantor Retained Annuity Trusts (GRATs)
GRATs are often used when a client holds assets expected to appreciate significantly, such as closely held business interests or concentrated investment positions. The structure allows future growth above a required IRS rate to pass to beneficiaries with potential transfer tax advantages, while the grantor receives annuity payments during the trust term.
GRATs can be useful, but they require careful timing and planning, particularly because the grantor’s death during the trust term may affect the intended result.
Intentionally Defective Grantor Trusts (IDGTs)
IDGTs are more technical than GRATs. These irrevocable trusts are typically structured so the grantor remains responsible for income taxes while the assets are removed from the taxable estate for estate tax purposes. In some plans, appreciating assets may be sold to the trust through an installment sale.
Because IDGTs involve significant legal, tax, and administrative considerations, they require close coordination with qualified estate counsel and tax advisors.
Spousal Lifetime Access Trusts (SLATs)
SLATs may be considered for married clients who want to remove assets from the taxable estate while preserving indirect access for family members. One spouse transfers assets to an irrevocable trust that names the other spouse as beneficiary, often with children or descendants as additional or remainder beneficiaries. SLATs can be effective, but they require careful planning, especially when both spouses create trusts or when future marital changes could affect access.
In each case, the trust structure may be sophisticated, but administration still depends on clear beneficiary information. Advisors and fiduciaries should consider who may be entitled to income, principal, notice, or remainder interests, and whether those individuals can be identified and located when needed.
Charitable and Multigenerational Planning Trusts
For clients whose goals extend beyond tax reduction, charitable and multigenerational trusts may play an important role.
Charitable Remainder Trusts allow a donor or other beneficiaries to receive income for a set term or for life, with the remaining assets eventually passing to charity. Charitable Lead Trusts work in reverse: income flows to a charity for a set period, with the remainder passing to family or other non-charitable beneficiaries.
Generation-skipping trusts and dynasty-style structures are designed to preserve wealth across multiple generations. These arrangements can support long-term family governance, but they can also become administratively complex. Over time, trustees may need to confirm descendant lines, locate remainder beneficiaries, or document relationships years after the original trust was created.
Structure Matters, But So Does Administration
For trustees, fiduciaries, trust officers, and estate counsel, sound administration depends on knowing who the beneficiaries are and having the documentation to support that determination.
That requirement becomes harder to meet in complex estates. Beneficiaries relocate, lose contact with family, or die without the estate being notified. Blended families may create unclear or disputed family lines. Trusts that span generations may name remainder beneficiaries who are difficult to identify decades later. Any of these gaps can create risk for the fiduciary responsible for distribution.
This is where HeirSearch supports the process. Since 1967, we have helped legal and trust professionals identify missing or unknown heirs, verify kinship, and document beneficiary status for probate, estate, and trust matters. Our work produces court-ready reports with transparent, non-percentage-based fees, giving fiduciaries and their counsel the documentation they need to administer estates with confidence.
If you are a fiduciary professional needing to establish heirship to satisfy the court, HeirSearch can help. We offer no-cost, no-obligation consultations, even if you are not planning to start a search immediately.
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