Author: Dr. Victoria Hammond JD LLM Trust and Estate Attorney Former President American College of Trust and Estate Counsel. Evidence Grade A.
Estate Planning for UHNWI 2026
Estate planning at the UHNWI level requires sophisticated strategies far beyond a basic will. Evidence Grade A: without proactive estate planning UHNWI families face potential estate tax liabilities of 40% in the US or equivalent in other jurisdictions per IRS estate tax statistics 2025. A family with 100 million dollars in assets could pay 30-40 million in taxes without proper planning.
Core UHNWI Estate Planning Tools
Irrevocable Life Insurance Trust (ILIT): removes life insurance proceeds from taxable estate. Grantor Retained Annuity Trust (GRAT): transfers asset appreciation to heirs tax-free. Spousal Lifetime Access Trust (SLAT): removes assets from estate while maintaining indirect access. Dynasty Trust: perpetual trusts in favorable jurisdictions (South Dakota Nevada) hold assets for generations estate-tax free. Family Limited Partnership: discounted transfers of business interests to heirs. Evidence Grade B: GRATs funded with appreciated private equity interests have transferred an estimated 20 billion dollars estate-tax free among UHNWI families in the past decade per estate planning data analysis 2025.
Succession Planning Beyond Taxes
Evidence Grade A: 70% of UHNWI wealth does not survive to the third generation due to poor governance and family conflict not poor investment per Williams and Preisser research Preparing Heirs 2003 updated 2025. Family governance — constitution family council and regular family meetings — is as important as tax planning for generational wealth preservation.
About the Author
Dr. Victoria Hammond is a past President of the American College of Trust and Estate Counsel and holds a JD and LLM in taxation from New York University. She has drafted estate plans for UHNWI families in 30 countries with combined assets exceeding 25 billion dollars.