Integrated Wealth Transfer and Tax Optimization for a Tech Executive

A Seattle area family with most of its wealth in one company’s stock, property in several states, and a spouse who is not a United States citizen.

$40M

Net worth

$30M

Investments (low basis)

$10M

Rental Property (multi-state)

2

Adult children to inherit

Balancing Ambition with Multi-Generational Wealth

A partner-level artificial intelligence engineer at a large technology company in the Seattle area came to us with his wife, who is not a United States citizen. Both are first-generation immigrants, and they have two adult children. Their net worth is roughly $40 million: about $30 million in investments, much of it a single low basis position in his employer’s stock, and about $10 million in rental property spread across several states. They reached financial independence years ago, and he keeps working out of a passion for artificial intelligence. They expect to spend about $10 million in their lifetimes and want the rest, roughly $30 million, to reach their children.

Allocation Goal

$10M

Lifetime Spend

$30M

Lifetime Spend

Maximizing the transfer of accumulated assets while maintaining current lifestyle parameters.

Their Goal Was Simple. Their Situation Was Not.

01

Estate Tax Exposure

Washington taxes estates at a threshold far below the federal one, and the federal exemption keeps shifting, so a family that feels comfortably under the federal line can be well over the state one.

02

A Spouse Who Is Not a Citizen

Assets left to a spouse who is not a United States citizen do not receive the unlimited marital deduction that citizen spouses rely on.

03

Stock That Is Expensive to Sell

The concentrated stock was expensive to sell, since much of it carried a very low cost basis and a large embedded gain.

04

Properties That Became a Job

Rental properties, heavily appreciated and scattered across several states, had become a job that neither they nor their children wanted.

One Plan, Not Four Separate Solutions

We built one plan rather than four separate solutions.

01

We sold the higher basis shares and diversified the proceeds, while holding the lowest basis shares inside the estate, where Washington’s community property rules can allow the basis to reset when the first spouse dies. The shares that would cost the most to sell became the most efficient part of the transfer.

02

Four million dollars of deferred compensation was laddered over 15 years in a conservative 65/35 allocation, so the family’s spending is funded by a predictable stream rather than by selling stock.

03

Working with their attorney, we funded two spousal lifetime access trusts with about $20 million across consecutive tax years, invested for long-term growth under a health, education, maintenance, and support standard, with the children’s access beginning at age 35.

04

We began annual conversions of pre-tax retirement money the family does not expect to spend, moving it toward the part of the plan intended for the children, and we hold the brokerage and cash accounts in a revocable living trust that becomes an irrevocable credit shelter trust when the first spouse dies, at which point the stepped-up assets can be gifted.

05

The properties follow a multi-year path rather than a single sale and a single large tax bill. They are exchanged into Delaware Statutory Trusts, which removes the landlord work, and then, after the required holding period, into an UPREIT, which keeps institutional real estate income and is far simpler to divide among heirs.

POST-PLAN WEALTH FLOW

SPENDING

Laddered income, no forced sales

HELD IN THE ESTATE

Lowest basis shares, for the reset

OUTSIDE THE ESTATE

Trusts, for the children

PROPERTY TRANSITION PATH

Rental Property, Several States

↓ (1031 Exchange)

Delaware Statutory Trusts

↓ (UPREIT Conversion)

One Plan Instead of Five Separate Ones

01

More than $20 million sits outside their taxable estate.

02

Their spending is funded without forced sales of company stock, and each asset is held in the account type that suits it.

03

The spouse’s situation is addressed now rather than discovered later.

04

The properties have a route to becoming income the children can inherit without becoming landlords.

What the family values most is knowing that what they built will reach their children in the form they intended.

Wondering What This Would Look Like for Your Family?

Spencer Graham works with families like this one from our Seattle area office. The first conversation is confidential and carries no obligation.