Diagnostic Summary · Portfolio Risk Assessment

What your estate

already owes.

Three figures from the public record. Each one represents a structural exposure that a properly documented family office eliminates before it becomes a filing.

01
Finding 01 of 03
$0M

Average Federal Estate Tax Liability

for portfolios above $25M at current unified credit thresholds

IRS Rev. Proc. 2023-34 · Applicable Exclusion Amount $12.92M

Source: IRS Statistics of Income Division, 2023

02
Finding 02 of 03
0%

Family Wealth Lost by the Third Generation

across all asset classes, inclusive of operating companies and real property

Williams & Preisser, Preparing Heirs (2003) · Confirmed Roy Williams Group Study

Source: Roy Williams Group longitudinal study, n=3,250 families

03
Finding 03 of 03
0

Structural Vulnerabilities Per Audit

average findings in a multi-entity review spanning trust, operating, and offshore structures

Internal aggregate · Fiduciary Advisory Group diagnostic review data, 2019–2024

Source: Fiduciary Advisory Group, n=148 completed diagnostics

Comparative Audit Report · Four Structural Domains

What a structured estate looks likeversus what most estates actually are.

Each row below represents a documented exposure pattern from our diagnostic review database. The left column is what we find. The right column is what we build.

Audit Section AP-01

Asset Protection

Creditor exposure across operating entities, real property, and liquid holdings

Critical

Operating Company Liability

Personal assets exposed to business creditors through piercing risk when entity formalities are not maintained across all operating subsidiaries

Segregated LLC or LP structure with documented formalities eliminates cross-entity exposure; charging order protection confirmed in domicile jurisdiction

Critical

Real Property Ownership

Direct title in individual name creates full judgment lien attachment risk and public record exposure of portfolio breadth

Series LLC or land trust holding with beneficial interest separation; no public record ties individual to specific property addresses

High

Offshore Trust Coordination

Offshore structures operating without coordinated domestic trust framework generate FBAR/FATCA compliance gaps and create jurisdiction conflicts on distribution

Integrated domestic-offshore trust architecture with qualified trustee, distribution committee, and annual PFIC/CFC review cycle in place

Elevated

Umbrella & Excess Liability

Standard umbrella policy written on personal lines without coordination with entity-level coverage creates gap layers between $5M and $25M exposure bands

Coordinated excess liability tower written across personal and entity lines; gap analysis documented and reviewed at each entity formation event

4 vulnerabilities documented in this section
Request Your Confidential Audit
Audit Section TE-02

Tax Efficiency

Federal estate, gift, and income tax exposure across current and sunset provisions

Critical

Estate Tax Exposure at Sunset

Portfolio above $7M (2026 projected exclusion) fully exposed to 40% federal estate tax on assets not transferred prior to TCJA sunset on January 1, 2026

Accelerated gifting program through SLATs, GRATs, and QPRTs completed before sunset; taxable estate reduced to below projected threshold with documented appraisals

Critical

GRAT Valuation Timing

No GRAT program in place; appreciation in operating company and real estate portfolio accumulates inside taxable estate without transfer at discounted valuation

Rolling 2-year GRATs funded with closely-held interests at IRS Section 7520 rate; zeroed-out structure transfers appreciation above hurdle rate to remainder trust

High

Income Tax Basis Planning

Irrevocable trust assets do not receive step-up at grantor death; low-basis positions trapped without swap power or decanting provision to reposition

Grantor trust status maintained with swap power; low-basis assets exchanged for high-basis assets pre-death; basis step-up captured on entire substituted portfolio

High

Dynasty Trust Jurisdiction

Trust sitused in state with Rule Against Perpetuities limit; multi-generational transfer plan truncated at 21 years beyond last measuring life

Trust decanted or reformed to South Dakota, Nevada, or Delaware perpetual trust jurisdiction; generation-skipping exemption fully allocated at formation

4 vulnerabilities documented in this section
Request Your Confidential Audit
Audit Section SR-03

Succession Readiness

Governance, transition authority, and continuity across operating entities

Critical

Operating Company Transition

No documented succession plan or buy-sell agreement; operating company value and control transfer dependent on probate proceeding or trustee interpretation of pour-over will

Buy-sell agreement funded with split-dollar life insurance; trusteed cross-purchase structure with independent trustee holds policies; triggering events documented

High

Family Governance Charter

No family constitution or investment policy statement; second-generation conflicts resolved through litigation or forced liquidation when patriarch authority is absent

Family governance charter with defined decision rights, distribution standards, and conflict resolution protocol; family council with independent advisor seat

High

Incapacity Planning

Durable power of attorney insufficient for multi-entity management; financial institutions may not honor aging DPOA; trustee succession undefined in revocable trust

Revocable trust as primary vehicle with defined successor trustee chain; institutional co-trustee for continuity; limited trustee powers memorandum for each entity

Elevated

Digital & Private Equity Assets

Crypto holdings, carried interest, and private fund positions not addressed in trust or estate documents; no letter of instruction; access credentials undocumented

Digital asset trust addendum executed; carried interest assignment provisions reviewed with fund counsel; encrypted credential memorandum held by institutional trustee

4 vulnerabilities documented in this section
Request Your Confidential Audit
Audit Section PE-04

Privacy Exposure

Public record footprint, beneficial ownership disclosure, and litigation targeting

Critical

Probate & Public Record

Estate assets and beneficiary identities become public record through probate; inventory filed with court creates searchable documentation of full portfolio composition

Fully-funded revocable trust avoids probate entirely; no court filing required; beneficiary identities and asset values remain outside public record

Critical

FinCEN Beneficial Ownership

Corporate Transparency Act reporting obligations unaddressed; entities formed prior to January 2024 past initial filing deadline; penalties accumulate at $500/day

BOI reports filed for all reporting companies; exempt entity analysis completed; ongoing compliance calendar established for new entity formations

High

Real Property Public Disclosure

Property tax records, deed filings, and mortgage documents tie individual name to specific addresses; litigation targets can map full real estate portfolio in under one hour

Nominee title or land trust holds all real property; beneficial interest not recorded; LLC member names shielded in non-disclosure state formation

Elevated

Social Engineering & HNWI Targeting

Public record exposure of wealth concentration creates targeting surface for litigation, kidnap-and-ransom exposure, and social engineering of estate counsel

Coordinated privacy architecture with security counsel; controlled public record footprint; family members not named in entity documents visible to public

4 vulnerabilities documented in this section
Request Your Confidential Audit
Client Profiles · Who We Serve

Three kinds of peoplealready sitting across this desk.

The engagement begins when you recognize yourself in one of these descriptions. The diagnostic confirms what you already suspect.

CLIENT-A

The Second-Generation Inheritor

Inheriting a portfolio assembled by a patriarch who built it through instinct rather than structure. The holdings are real — the documentation is not. You are navigating your first estate transition without a map, and the clock on TCJA sunset is not waiting for you to get oriented.

First estate transition
$10M–$75M inherited portfolio
No existing trust review
Immediate TCJA exposure
Sunset deadline: December 31, 2025
CLIENT-B

The Founding Patriarch

You built it across three decades and four entity types. The operating company, the real estate holdings, the offshore structure your attorney set up in 2009 — they have never been reviewed as a system. Every piece was right when it was built. The question is whether they still work together.

Multi-entity holdings
Operating company + real estate
Offshore trust coordination
Succession undefined
Average structural gap: 23 vulnerabilities per audit
CLIENT-C

Outside Counsel

You need a co-pilot fluent in GRAT valuations, dynasty trust jurisdictions, and the intersection of income and transfer tax planning. Your client's estate is sophisticated enough that you want a second opinion before the filing. We work alongside counsel — not around them.

GRAT / IDGT coordination
Dynasty trust jurisdiction analysis
Valuation discount review
Co-counsel engagement
Available for co-counsel engagement
Practice Fluency
SD · NV · DE
Dynasty Trust Jurisdictions
IRC §2702
GRAT Valuations
CTA 2024
FinCEN BOI Compliance
TCJA §2010
Sunset Planning
IRC §684
Offshore Trust Transfers
Rev. Proc. 2023-34
Exclusion Amount Planning
Gated Resource

The Family Office Readiness Checklist

Eight sections. 112 line items. The same framework used in every Fiduciary diagnostic engagement — condensed into a PDF you can work through before the first call.

Trust document review checklist (23-point audit)
Entity formality maintenance schedule
TCJA sunset planning timeline
Dynasty trust jurisdiction comparison matrix
FinCEN BOI compliance checklist
Family governance framework template
Digital asset trust addendum guide
Offshore trust FBAR/FATCA coordination checklist
Format: PDFPages: 18Updated: Q1 2026

Download the Checklist

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