The Agreement That Cost Two Children $35 Million Each
July 30, 2026
A family unanimously agreed to end Mom's QTIP trust early and hand everything to Dad. In McDougall v. Commissioner, the Tax Court just priced that handshake at $35,141,321 per c...
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Safeguarding what belongs to others.
Plain-English essays on trust administration, estate planning, and fiduciary duty — the craft of holding what belongs to someone else, and answering for it. New essays land here first, then on LinkedIn. Subscribe below.
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July 30, 2026
A family unanimously agreed to end Mom's QTIP trust early and hand everything to Dad. In McDougall v. Commissioner, the Tax Court just priced that handshake at $35,141,321 per c...
July 29, 2026
Nearly 90% of advisors accept the age-90 or age-95 default in their planning software. For a trustee owing impartiality under N.C.G.S. 36C-8-803, that unexamined number quietly ...
July 27, 2026
A disbarred attorney emptied the trust he drafted, then argued he was too broke to pay the penalty. In Moramarco v. Nowakoski, California held that Probate Code 859 doesn't ask ...
July 24, 2026
Kristian Pfeffer on Conagra's 50% dividend cut and $2 billion goodwill writeoff, and why a trustee who bought the yield instead of the business gets caught flatfooted.
July 23, 2026
An IRS private letter ruling let a grieving spouse fix a botched QTIP election under Sec. 2056(b)(7). The relief exists, but the cleaner path is a protective election the first ...
July 22, 2026
Kristian Pfeffer on Sec. 530 'Trump Accounts' and the moment they quietly become a traditional IRA — handing an eighteen-year-old both the money and the duty to manage it.
July 20, 2026
Cerulli Associates finds tax optimization is now the top development priority for wealth platforms, two years running. For a trustee, that isn't a product trend — it's a duty th...
July 19, 2026
Kristian Pfeffer on how six years as a U.S. Army logistics officer — accountable for $15M of other people's property — became the foundation for a career in trust administration...
July 16, 2026
New IRS regs make certain CRAT schemes listed transactions, with steep penalties for skipping disclosure. Call it more paperwork if you like — a CRAT that puts the charity first...
July 15, 2026
A mega-IPO with no real price discovery, billions in losses, dual-class shares, and immediate index inclusion — landing in retirement plans by default. A fiduciary owes benefici...
July 15, 2026
In C.S. v. R.H., a husband placed $111 million in irrevocable trusts yet kept trustee and investment control. A New York divorce court folded it into the marital estate. The tax...
July 14, 2026
Twilio's turnaround is a preview of a wider shift: AI is a labor resource, and the advantage belongs to the people who teach it — not the ones who bark orders at it.
July 13, 2026
Trust companies keep exiting special needs trusts or pricing out everyday families. A (d)(4)(A) trust protects a child's SSI and Medicaid only if someone will administer it — an...
July 12, 2026
The IRS named certain charitable remainder annuity trust transactions as listed transactions. The structure served real donors too — but now non-disclosure, not the strategy its...
July 11, 2026
IRC §1202 lets founders exclude gain on qualified small business stock, and trust stacking can multiply it. A powerful tool for concentrated wealth — but only if the holding-per...