UpstreamNew Hampshire ยท Irrevocable
The problem

You own something you can't afford to sell.

Advisors call it trapped capital. Upstream unlocks it, using an estate tax allowance your parents will never use.

Four minutes. No email until the end.

The arithmetic

Founder stock bought for $250,000. Worth $6,000,000 today. You're in Washington, and both your parents are living.

Sell it today
$1,771,000

A combined 30.8% on a built-in gain of $5,750,000.

Held in Upstream
$0

Your parents hold $26,000,000 of unused allowance. The whole position is covered.

The instrument

A New Hampshire trust with one unusual clause.

Five named seats, and a single provision that does the work.

Grantor
You
You create it and fund it.
Investment director
You
Every buy, sell, and vote stays yours.
Trustee
Independent, in New Hampshire
Sole power over distributions. You can replace them at any time, for any reason.
Trust protector
Independent
The only person who can switch the basis feature on.
Your parents
Beneficiaries
They own nothing, receive nothing, and sign nothing.
The clause

The protector gives each parent a power that exists only on paper, and only at death.

Because they hold it when they die, the tax code counts those assets in their estate. Because their estate is well under the exemption, no tax is owed. The basis resets anyway. The assets never move, and nothing passes through anyone's will.

The trade

What you keep, and what you give up.

The second list is short, and it's the reason the first one holds.

You keep
Every investment decision
The right to swap assets in and out
The power to fire the trustee, without a reason
A veto on distributions to anyone but you
Your full $15M gift exemption, untouched
Parents who never sign anything
You give up
The right to demand money back
Simplicity. You pay the trust's income tax yourself
Reversibility. It is irrevocable
The estate tax benefit. This is a capital gains strategy
Fit

Five assets. One question about your parents.

Upstream only works on things carrying a built-in gain. There is no cash option, because cash has no gain to erase.

Public stock
Private or pre-IPO stock
Real estate
A business or LLC interest
Crypto
Cash
Is one parent worth comfortably under $15 million?

That's the whole test. The gap between what they're worth and their exemption is the allowance Upstream borrows. It expires unused at their death and benefits nobody. Two living parents means two allowances and two resets.

Next

What is it worth on your position?

Six questions. A real number at the end.

See what it would save you

Illustrative only. Figures are hypothetical and depend on your cost basis, your state, your parents' circumstances, and correct execution. Upstream is an irrevocable trust structure; whether it suits you is a question for your own attorney and tax advisor. Nothing here is legal or tax advice, and nothing here creates an attorney-client relationship.