
Eight conversations that protect a $30M+ estate — and the liquidity question underneath all of them
Estate planning at the $30M+ level is not the same exercise as estate planning for an affluent household. The instruments are more technical, the tax exposure is larger, and the wealth is usually concentrated in assets that do not divide cleanly. The advisor who can hold an intelligent conversation across this terrain — without pretending to be the attorney — keeps a central seat at the table for the client’s largest decisions.
This guide is built for that advisor. It walks the eight conversations that matter for an ultra-high-net-worth estate, in plain English, with the practical red flags to listen for in each. It closes with a diagnostic — the Estate Liquidity Stress Test — that you can run across your own book this week. It is not legal or tax advice, and it is not a product brochure. It is a working reference, written by a desk that designs the structures these conversations eventually require.
Before any instrument, understand the balance sheet. For most UHNW families the wealth is concentrated and illiquid — an operating business, concentrated stock, commercial or development real estate, partnership interests. These assets produce the family’s return precisely because they are not sitting in cash. The first question is not “what’s it worth?” It is “how much of it could become cash quickly, and at what cost?”
More estate plans fail on titling than on strategy. Assets that pass outside the will — by beneficiary designation, joint ownership, or operating agreement — can quietly override the most carefully drafted documents. For business owners, how the entity is owned and what the buy-sell agreement says often matter more to the estate outcome than the will itself.
RIAs do not draft trusts, but they should be conversant in what each one does and when it tends to appear. In plain English:
| Instrument | What it does, in one line |
|---|---|
| ILIT | Irrevocable life insurance trust — owns a policy so the death benefit passes outside the taxable estate. |
| SLAT | Spousal lifetime access trust — moves assets out of the estate while a spouse retains indirect access. |
| GRAT | Grantor retained annuity trust — transfers asset appreciation to heirs with minimal gift-tax cost. |
| Dynasty trust | Holds wealth across multiple generations, outside the estate at each one. |
| IDGT | Intentionally defective grantor trust — freezes asset value in the estate while growth passes to heirs. |
Wealth transfer is a timing game as much as a structuring game. Annual exclusion gifts, lifetime exemption use, and valuation discounts on closely held interests are the ordinary levers — but the larger strategic question is the federal estate-tax exemption itself, and the scheduled changes advisors are watching. The exemption level is a moving target set by legislation; rather than anchor to a number that may change, the durable point is this: families with large estates should know what their exposure is under current law and what it becomes if the law shifts.
For the founder, the estate plan and the succession plan are the same plan. Who runs the business, who owns it, how the non-active heirs are made whole, and how the whole thing is valued at transfer — these decisions drive the estate’s liquidity need more than any other. A family that wants the business to pass intact has, by definition, decided not to sell it to raise cash. That decision has to be funded from somewhere else.
Here is the eighth conversation the other seven were leading to. A large, illiquid estate routinely faces obligations at transfer that demand cash: settlement and transfer costs, the equalization of inheritances when the marquee asset cannot be divided, the buy-out of a co-owner, or simply the replacement of wealth meant to pass intact. The estate is large. At that moment, it is also short of liquidity.
There are only a few ways to meet that need: sell assets (often the very assets the family wanted to keep), borrow against them, or have life insurance deliver the cash — typically through an ILIT so the benefit passes outside the estate. The hard question is how to pay for that coverage on the scale these estates require. Funding the premiums by liquidating invested capital interrupts compounding, can realize gains, and forces a sale on the policy’s schedule rather than the family’s. Financing the premiums instead — the premium-financing strategy — lets the capital stay invested while the protection is put in place.
For many UHNW families, charitable intent is real and also tax-efficient — donor-advised funds, charitable remainder and lead trusts, and private foundations each serve different mixes of legacy, control, and tax outcome. The advisor’s role is rarely to pick the vehicle; it is to surface the intent early enough that it can be structured rather than improvised, and to coordinate it with the rest of the plan.
The estate attorney drafts. The CPA models the tax. The insurance or finance specialist designs the funding. None of them owns the relationship the way you do. The highest-value role an RIA can play is quarterback — surfacing the issues early, convening the right specialists, and making sure the parts reconcile into one plan rather than three disconnected ones. That role is also what keeps you central to the client as the plan, and the wealth, move.
Run this across your book. Pick your ten largest households and answer each prompt for each one. Every box you cannot check confidently is a conversation worth having — and a client worth a closer look.
Insurance: Life insurance products, including Indexed Universal Life (IUL), are insurance contracts issued by licensed life insurance carriers. Policy performance — including crediting rates, cap rates, participation rates, and cost of insurance charges — is not guaranteed. Past performance is not indicative of future results. Products are subject to underwriting approval and vary by state. Loans and withdrawals reduce policy cash value and death benefit and may have tax consequences. Goheen Insurance acts as a licensed insurance broker. Nothing herein constitutes an offer or solicitation to purchase any insurance product.
Premium Finance: Premium financing involves borrowing from a third-party lender to fund life insurance premiums. This strategy carries significant financial risk, including variable loan rates tied to SOFR, collateral requirements, margin call exposure, and the possibility that policy cash values may be insufficient to repay the loan. The arbitrage between loan costs and policy crediting rates is not guaranteed and may produce negative outcomes. Suitability must be evaluated on an individual basis by qualified legal, tax, and financial professionals. Hypothetical illustrations are for educational purposes only and do not represent actual client outcomes.
Tax & Legal: Nothing herein constitutes legal or tax advice. Tax information reflects current law as of the date of publication. Tax law is subject to change. Consult a qualified attorney and tax advisor regarding your specific circumstances before implementing any estate planning strategy.
Investment: Goheen Insurance — A Simplicity Company — is not a registered investment adviser and does not provide investment advice. This publication is for informational and educational purposes only. References to market rates, indices, or economic conditions are provided for context only and do not constitute investment recommendations. Past market performance does not guarantee future results.
Goheen Capital is a brand name of Goheen Insurance, a Simplicity Group company. This material is intended for U.S. financial professionals and the clients they serve. It is educational in nature and is not an offer, solicitation, or recommendation of any product or strategy.