1. Estate & Tax Law Evaluation and Architecture
Review trusts, wills, deeds, and ownership structures
Spot estate inclusion under IRC §§2036 (retained interest), 2038 (revocable control), 2041 (powers of appointment), 2042 (life insurance ownership)
Flag probate exposure, outdated titles, and poor funding
Recommend lifetime gifting (IRC §2503), step-up strategies (IRC §1014), and fix trust design flaws
Key Cases: Estate of Maria B. Strangi v. Commissioner, Estate of Powell v. Commissioner, Estate of Jordahl (life insurance)
2. Entity & Structure Mapping
Analyze all entities: LLCs, LPs, S-Corps, Foundations, Trusts
Detect commingling, retained control, improper elections, or undercapitalization
Map asset flow and legal identity conflicts (individual vs entity ownership)
Restructure for liability shielding, tax reduction, and succession
Key Codes: IRC §7701 (entity classification), §1361 (S-Corp eligibility)
Key Cases: Moline Properties v. Commissioner, Boulware v. United States
3. Asset Class Review & Alignment
Audit real estate, stocks, insurance, business shares, crypto, retirement
Fix title mismatches, ILIT flaws (IRC §2042), and funding gaps
Correct valuation (IRC §2031), TOD issues, or Form 709 gift tax errors
Align asset control, legal ownership, and tax treatment
Key Cases: Crummey v. Commissioner (gifting), Estate of Gloeckner (business valuation), Estate of Rapp (crypto/tax treatment)
4. Tax Strategy Integration
Coordinate planning across income (IRC §61), cap gains (§1201), corporate (§11), and estate tax (§2001)
Manage trust tax rules (Subchapter J: IRC §§641–685)
Use charitable tools: PFs (§4940), DAFs (§170), CRTs (§664)
Optimize elections: S-Corp (§1362), disregarded entity (§301.7701-3), 501(c)(3)
Key Cases: Estate of Tamulis (CRTs), United States v. Marshall (trust distribution)
5. Philanthropy & Legacy Planning
Setup or review Foundations, Donor-Advised Funds, and CRTs
Align giving with tax advantages (IRC §170, §501(c)(3)) and legacy goals
Create governance systems, succession plans, and grant strategies
Structure for public visibility or private control
Key Codes: IRC §§170, 4941–4945 (self-dealing, grantmaking)
Key Cases: Foundation for Human Understanding v. United States, Bob Jones University v. United States
6. Advisor Coordination & Oversight
Synchronize legal, tax, insurance, investment, and real estate advisors
Provide one unified roadmap to reduce conflict and confusion
Train internal team or family office staff to monitor ongoing compliance
Avoid siloed decisions and missed opportunities
Key Codes: Not codified—this is the "substance over form" test in practice
Legal Principle: Commissioner v. Court Holding Co. — the IRS looks at economic reality, not labels
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