OBBBA-Optimized Defense
$15M Exemption·OBBBA-Optimized·Lifetime Transfer·Zero Tax Engineered

The Permanent $15M Exemption.
$30MFor Couples.
Every Dollar Defended.
Architected By VFC.
Permanent · OBBBA-Locked · Aggressively Deployed

The One Big Beautiful Bill Act (OBBBA) locked the lifetime gift and estate tax exemption at a permanent $15 million per individual ($30 million for married couples)— the most aggressive estate tax environment HNW families have seen in a generation. The window to deploy is now. The strategies are precise. The math is overwhelmingly in your favor.

VFC engineers an aggressive lifetime transfer architecture that strips appreciating business and investment assets out of the taxable estate now— using only a fraction of the expanded exemption — while engineering the residual tax exposure to be covered by tax-free life insurance death benefit. The end result: estate tax bill at death of zero. Wealth delivered to heirs: 100%.

1 of
Very Few
Firms In America

Estate Tax Strategy Coordinated With The Entire Financial Life.

Estate tax planning is not a one-time legal exercise — it is a multi-decade strategic discipline that has to coordinate with income tax, capital gains, business succession, and insurance architecture. VFC is one of the only firms in Americarunning estate tax strategy insidethe same practice as income tax, investment, retirement, and insurance — so nothing falls through the cracks between specialists who never speak to each other.

The 2026 Framework

The OBBBA Estate Tax Environment.

Permanent · Predictable · The Most Aggressive HNW Planning Window In A Generation
$15M
Per IndividualPermanent lifetime exemption
$30M
Married CouplesCombined permanent exemption
40%
Federal RateOn amounts above exemption
$19K
Annual ExclusionPer recipient, per year
The Goal Behind Every Plan

Strip Appreciating Assets Now. Make The Tax Disappear At Death.

VFC's estate tax mission is simple to state and difficult to execute. Move appreciating business and investment assets out of the taxable estate during life— using FLP discounts, dynasty trusts, intentionally defective grantor trusts, and aggressive annual gifting. Then position permanent life insurance in an ILIT to cover any residual estate tax liability tax-free. The result is an estate tax bill of effectively zero, no matter how large the underlying wealth grows.

Goal At Transfer

0%

Estate tax liability paid out of pocket. Death benefit covers any residual exposure. Wealth delivered to heirs: 100%.

Eight Tax Mitigation Strategies

How VFC Defends Every Dollar Of The Estate.

01

Aggressive Lifetime Exemption Use

Execute lifetime transfers nowto lock in the $15M/$30M permanent exemption. Moving appreciating business equity into irrevocable trusts strips all future growth out of the taxable estatewhile using only a fraction of the expanded threshold.

02

FLP With Valuation Discounts

Non-voting business interests transferred into a Family Limited Partnership qualify for steep valuation discounts (typically 20-40% off)for lack of marketability and control. Millions of dollars of equity transfer using a fraction of the exemption.

03

Intentionally Defective Grantor Trust (IDGT)

The grantor continues to pay income tax on trust earnings — functioning as a tax-free annual gift to the trust beneficiaries— while removing all trust assets and appreciation from the taxable estate.

04

Generation-Skipping Transfer (GST) Trust

Use the GST exemption to move wealth across multiple generations of taxation in a single transfer— protecting both children and grandchildren from estate tax at every transfer point.

05

Annual Gifting Calendar

The $19,000 per recipient annual exclusion ($38K for couples) compounds dramatically over decades. A coordinated multi-recipient gifting program transfers millions over timewith zero exemption use and zero tax.

06

Charitable Remainder Trust (CRT)

Appreciated assets contributed to a CRT generate an immediate income tax deduction, lifetime income stream, and the eventual gift of the remainder to a chosen charity or family foundation— while removing the asset from the estate.

07

Permanent Life Insurance In ILIT

The architecture that engineers the residual tax to zero. Permanent insurance held in an irrevocable trust pays out tax-free under IRC §101— positioned specifically to cover any remaining estate tax at the moment it's owed.

08

SLAT & Spousal Lifetime Trust

Spousal Lifetime Access Trust allows one spouse to fund a trust for the benefit of the other while still removing the assets from the taxable estate of both spouses— preserving family access without preserving tax exposure.

The Numbers Behind The Strategy

Estate Tax Exposure: Standard Planning vs. VFC Architecture.

The bars below model federal estate tax owed at death for four different estate sizes under standard estate planning vs. the full VFC architecture. The differential is the dollar value of the planning work.

Estate Tax Owed At Death

Standard Planning vs. Full VFC Architecture· By Total Estate Size

Standard Planning
VFC Architecture
$25M EstateSingle Owner
Std
$4M
$4.0M
VFC
$0
$0
$50M EstateHNW Family
Std
$14M
$14.0M
VFC
$0
$0
$100M EstateUHNW Family
Std
$34M
$34.0M
VFC
$0
$0
$200M EstateMulti-Gen
Std
$74M
$74.0M
VFC
$0
$0

Across every estate size, the VFC architecture engineers the federal estate tax bill down to effectively zero— through layered exemption use, valuation discounts, trust structures, and tax-free life insurance death benefit positioned outside the estate.

What VFC Estate Tax Planning Delivers

Permanent. Engineered. Tax-Free At Transfer.

$15M
Permanent ExemptionLocked under OBBBA
8
Active StrategiesDeployed per plan
40%
FLP DiscountTypical valuation reduction
0%
Estate Tax GoalEngineered final liability
Calculate Your Exposure

One Number You Should Know: Your Projected Estate Tax Bill.

Most HNW families have never modeled their projected estate tax exposure under current law. VFC calculates it in the diagnostic phase— projecting your estate forward, applying current OBBBA framework, and showing exactly what your family would owe under standard planning vs. the full VFC architecture.

The diagnostic is yours regardless of whether you continue with us. No cost. No obligation.

What’s Included · No Cost

Estate Tax Exposure Diagnostic.

Current Estate ValuationTotal estate calculated across business, real estate, retirement, investments.
20-Year ProjectionEstate growth modeled forward with realistic assumptions.
Standard Planning ExposureEstate tax owed at death under typical planning.
VFC Architecture ExposureEstate tax owed at death with full strategy stack deployed.
Strategy RecommendationsSpecific moves to close the gap, sequenced and prioritized.
Insurance Coverage CalculationDeath benefit size required to engineer residual to zero.
Valentine Financial Consultants · Estate Tax Strategy— the OBBBA-optimized defense of every dollar of family wealth.

The Permanent Exemption Window Is Open. Deploy The Architecture Now.

Under OBBBA, the $15M permanent exemption combined with aggressive lifetime transfer strategies creates the most powerful HNW estate planning environment in a generation. The strategies don't deploy themselves. The clock is running on appreciation.

Begin Your Estate Tax Architecture