The 35% Penalty on Money You Never Owed Tax On
When you create a foreign trust, you step into one of the most unforgiving reporting regimes in the entire Internal Revenue Code. The rules live in IRC § 6048.
When you create a foreign trust, you step into one of the most unforgiving reporting regimes in the entire Internal Revenue Code. The rules live in IRC § 6048.
The “trustee might refuse” critique of the Bridge Trust® collapses under the statutory framework, contractual reality, and 30 years of operating history.
The biggest criticism of the Bridge Trust® is that the offshore trustee can simply “say no” during duress. That critique misunderstands how the structure actually works. This article explains why the Special Successor Trustee’s commitment is made at formation — not at trigger — and why the same “maybe” argument applies equally to fully foreign Cook Islands trusts. Includes real-world case analysis, trustee mechanics, Cook Islands law, and the four pillars courts actually evaluate: timing, control, jurisdiction, and collectibility.
SLATs forfeit the step-up, lack creditor protection, and risk reciprocal trust doctrine collapse. The Dynasty Bridge Trust™ solves all four problems. Slug: slat-vs-dynasty-bridge-trust
Traditional Dynasty Trusts and SLATs forfeit the step-up in basis at death. The Dynasty Bridge Trust™ preserves it. Here’s the multi-million dollar difference.
OBBBA permanently locked the $15M/$30M estate tax exemption. For most families, sequencing dynasty trust planning beats premature commitment.
The One Big Beautiful Bill Act raised the federal estate tax exemption to $15 million per person — $30 million for a married couple. Most successful couples saw that number and assumed the estate planning conversation was over. It isn’t. The OBBBA left one critical gap completely untouched: the GST exemption is not portable between spouses. Whatever exemption the first spouse doesn’t allocate before death is gone permanently. For a married couple at $12 million today, that gap costs their family $14.6 million by the time the second spouse dies. Here’s the math — and why the Dynasty Bridge Trust is the right structure for couples who think they’re below the threshold.
Is the Bridge Trust® Really a Domestic Trust? No. The Bridge Trust® is a foreign trust in legal character from the day it is executed. “Domestic” is its IRC §7701 tax classification, not its legal situs. Two statutory tracks, explained.
If you’ve started hearing the term “dynasty trust” from your financial advisor, your CPA, or in a conversation about generational…
Your client has a plan for what happens when they die. They may not have a plan for what happens when they get sued while they’re still alive — or what happens to the $89 million that gets extracted from their estate across the next two generations. This article is written for the insurance producer who already sits across from that client.