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.
Founder stock bought for $250,000. Worth $6,000,000 today. You're in Washington, and both your parents are living.
A combined 30.8% on a built-in gain of $5,750,000.
Your parents hold $26,000,000 of unused allowance. The whole position is covered.
Five named seats, and a single provision that does the work.
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 second list is short, and it's the reason the first one holds.
Upstream only works on things carrying a built-in gain. There is no cash option, because cash has no gain to erase.
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.
Six questions. A real number at the end.
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.