PRACTITIONER REFERENCE GUIDE · LIKE AIR IN THE ROOM

Estate Planning Decoded

By Philip A. Baratelli, CPA, MBA · Baratelli Institute · Edition 1

THE FOUNDING THESIS

"Estate planning and trusts are like air in the room of a family office. They surround all discussions."

Family offices are normally created by late-career individuals with a need to think about estate planning — which is why estate planning and trusts surround every conversation in the family-office room. The estate-planning reference for the practitioner who has to translate the attorney's memo into a client decision on Wednesday morning. The OBBBA-permanent $15M / $30M exemption changed the playbook — defensive 2023–2025 strategies are now offensive opportunities. GRATs, IDGTs, SLATs, ILITs, dynasty trusts, charitable remainder trusts, the §6166 / §303 / §2032A toolkit, the family LLC, and the conversations that have to happen with the client before any of it gets executed. The companion volume to Family Office and to Trust Administration — creating the plan is half the work; administering it is the other half, and a different guide.

22chapters

1companion Excel workbook

OBBBA-updated for post-2025

$149Buy on Gumroad → ★ Read a free chapter → ↓ Preview the inside pages

Who this guide is for

The guide is written for the actual professionals who do this work — and the people who serve them. Each section contains material that will be useful to multiple audiences, but the persona-routing table below tells you where to start.

You are…	Start with these chapters
Sitting estate attorney drafting documents	Ch 4 GRATs · Ch 5 IDGTs · Ch 6 SLATs · Ch 7 ILITs · Ch 9 Dynasty Trusts · Ch 13 §6166 · Apx B Drafting Checklist
Wealth advisor / RIA translating the plan	Ch 1 The OBBBA Reset · Ch 2 The Conversation · Ch 11 The Annual Exclusion · Ch 16 Family LLC · Ch 21 The Spouse Who Doesn't Know
CPA on the family's account	Ch 12 Gift Tax Mechanics · Ch 13 §6166 · Ch 14 §303 Stock Redemption · Ch 18 Trust Income Taxation · Ch 19 §645 Election
Family-office principal coordinating the team	Ch 2 The Conversation · Ch 9 Dynasty Trusts · Ch 16 Family LLC · Ch 17 The Family Foundation · Ch 22 Next-Gen Onboarding
Founder facing a liquidity event	Ch 1 OBBBA Reset · Ch 4 GRATs · Ch 8 Charitable Remainder Trust · Ch 11 Annual Exclusion · Ch 15 The Pre-Liquidity Trust Fund

Page counts are approximate.

PART I — The Reset

1The OBBBA Reset — From Defense to Offensep1

2The Conversation You Have With the Client Firstp13

3Reading the Existing Estate Plan — What Was Built for the Old Cliffp23

PART II — The Trust Toolkit

4GRATs — The Workhorse Strategy, Recalibratedp33

5IDGTs — Sale to Intentionally Defective Grantor Trustp45

6SLATs — The Spousal Lifetime Access Trust Trap (and How to Avoid It)p57

7ILITs — The Insurance Trust Mechanicsp67

8Charitable Remainder Trusts — The Liquidity-Event Companionp77

9Dynasty Trusts — Picking the Jurisdictionp87

10QPRTs and Other Personal-Asset Trustsp97

PART III — Gifting & The Exemption

11The Annual Exclusion — Mechanics and the Crummey Letterp105

12Gift Tax — Form 709 in Practicep113

13§6166 — Estate Tax Deferral on Closely-Held Businessp123

14§303 — Stock Redemption to Pay Death Taxesp135

15The Pre-Liquidity Trust Fund — Timing With the LOIp145

PART IV — Holding Structures

16The Family LLC / FLP — Build, Operate, Defend the Discountp155

17The Family Foundation — When DAF Is Not Enoughp169

18Trust Income Taxation — DNI, Throwback, the §645 Electionp181

19§645 Election — Combining Trust and Estate for Tax Purposesp191

PART V — The Family Layer

20The Family Meeting — Cadence, Agenda, and What Not to Sayp199

21The Spouse Who Doesn't Know — Closing the Communication Gapp209

22Next-Gen Onboarding — At 18, At 25, At 35p219

PART VI — Special-Needs Architecture (New)

23Special Needs Trust Architecture — Variants, ABLE, LOI, Trustees, Two-Tier Fundingp229

24Benefit Preservation Planning — Medicaid, SSI/SSDI, Florida iBudget, §213(d), ILIT Sizingp235

Appendices

AOBBBA-Permanent Exemption Planning Decision Treep231

BTrust Drafting Checklist by Vehiclep239

CState-by-State Estate Tax Gridp247

DAI Tool Prompts (40+ practitioner-grade prompts)p255

EGlossary of Estate-Planning Termsp263

FIndex with Page Referencesp273

Preview the inside pages

Sample pages from the actual guide — cover, table of contents, persona routing, sample chapter openers, and back matter. These are the actual pages that ship; not marketing renders.

Cover

Table of contents

Persona-routing

Part I — OBBBA reset

GRATs chapter

SLAT trap

Dynasty trust mechanics

§6166 deferral

Family LLC

Family foundation

Next-gen onboarding

Back matter / glossary

What's actually in the bundle

1. The reference guide (PDF)

22 chapters + 6 appendices. Searchable, hyperlinked TOC and index. AI prompts inline at section boundaries (40+ across the book). Single-user license.

2. The companion Excel workbook (XLSX)

GRAT zeroed-out calculator, IDGT sale-to-trust scenario tab, SLAT reciprocal-trust risk analyzer, family LLC discount tracker, §6166 deferral schedule, §303 redemption sizing, charitable remainder trust scenarios, and the OBBBA exemption-runway model.

3. The OBBBA-permanent exemption planning decision tree (Apx A)

The visual decision tree for what to gift now (and how) given a permanent $15M / $30M exemption — by client net worth, by liquidity profile, by family structure, by state of domicile.

4. The state-by-state estate tax grid (Apx C)

12 states + DC have a state-level estate or inheritance tax. The grid shows thresholds, rates, portability, and the domicile-change mechanics that turn an OBBBA-clean federal plan into a clean state plan as well.

Plus: Free live tools derived from this guide

Free interactive tools at tools.baratelliinstitute.com run the math from the guide on your scenario. No purchase required.

Estate Tax Sunset Headroom Trust Selector Estate Planning Business Valuation Estate Planning for Collectibles

Editorial provenance

The Guide has gone through a 6-voice estate panel (3 estate attorneys including a §6166 specialist, 3 estate CPAs including a Form-709 specialist) plus a compliance review covering current IRS guidance, post-OBBBA technical corrections, and 12-state estate-tax overlay.

Every issue flagged in review has been folded into the text. The guide is in final pre-launch polish.

About the author

Philip A. Baratelli, CPA, MBA — Founder, Baratelli Institute. Ponte Vedra Beach, Florida.

20+ years in operating finance and M&A. The guides in this library are the references he wished existed when he was doing the work.

Estate Planning Decoded

$149 Single-user license · PDF + Excel workbook + sample artifacts

Companion Excel workbook
Free updates for 12 months after purchase
License also covers a delegate working on the same client file

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