Research, scenario modeling, and matter management for the estate planning attorneys, trust & estates groups, CPAs serving high-net-worth clients, tax attorneys, multi-state planners, and wealth planners who structure significant wealth. Primary-source citations. Currency-tracked. Refuses to fabricate.
One research engine across the full surface of an estate & tax practice —
The cited authority is always IRC, Treasury Regs, IRB-published guidance, written determinations, court cases, state codes, or treaties.
Effective dates, supersession, and amendment history are first-class fields. The pipeline filters on currency before reranking.
When the corpus does not contain sufficient authority, the system says so. It does not extrapolate from training data.
Every output ships with a prompt hash, model version, and retrieved chunk IDs. Two practitioners running the same query against the same corpus state get the same answer.
Title 26 USC parsed from Office of the Law Revision Counsel USLM XML. 26 CFR ingested from eCFR Versioner. IRB items scraped weekly. PLRs/TAMs/CCAs from the written-determinations index. Court opinions via CourtListener bulk + licensed citator. Section-aware chunking preserves the full IRC hierarchy.
Every substantive proposition in synthesis output must trace to a pinpoint cite drawn from the retrieved corpus. The synthesis prompt enforces this absolutely; post-processing verifies every inline marker resolves to a real document.
Citation precision
98.4%
Hallucination rate
< 0.6%
Currency accuracy
99.1%
OBBBA made the doubled exemption permanent. Our retrieval filter sees that. Pre-2026 sunset planning advice is flagged as historical context, not current authority. Effective dates and supersession are first-class fields, not afterthoughts.
Two refusal layers. First a retrieval-side threshold: if reranked chunks score below 0.3 normalized, synthesis is skipped. Second the prompt itself instructs Opus to refuse when authority is insufficient and return suggested next-step IRC sections instead. Out-of-corpus refusal rate on the eval set: 96.8%.
Naive RAG embeds your question against the entire corpus, then leans on an LLM to filter out 99% of what came back. We do the inverse: Haiku 4.5 classifies every chunk against a canonical taxonomy at ingest, and Sonnet 4.6 narrows the candidate pool by tag intersection before embedding search runs. Smaller pool → fewer tokens in synthesis → lower bill.
Each chunk is classified against seven dimensions: document_class, issue_area, scenario_tag, complexity_tier, net_worth_band, time_horizon, jurisdiction_tag. Free-form tags are rejected; only canonical values persist.
A Sonnet call analyzes the practitioner's question and emits a tag-filter set. SQL pre-filters chunks by GIN-indexed array intersection. Pool shrinks from millions to thousands in under 200ms.
Opus 4.7 sees only the top reranked candidates. Smaller input context = fewer tokens = lower internal cost. We share the savings: the routed op costs 550 credits vs. 750 for the unrouted version.
Below: three chunks from the seed corpus showing how primary authority, practitioner interpretation, and superseded content are differentiated. Authority status is structural — the synthesis engine knows to cite the first two and never cite the third.
Tags: estate_tax_federal · unified_credit · portability_dsue · SLAT · BYPASS_TRUST · GST_DYNASTY · complexity:foundational · net_worth:15m_50m,50m_250m,over_250m
Tags: grantor_trust_rules · gift_tax_federal · IDGT_SALE · IDGT_GIFT · SLAT · BENEFICIARY_DEFECTIVE_TRUST · complexity:advanced
Superseded by OBBBA (Jul 2025). time_horizon=historical_superseded. Never retrieved unless query is explicitly historical.
Every strategy in the matcher carries hard-coded eligibility gates, weighted positive signals, contraindications, a deterministic quant model, the primary authorities supporting it, and the pitfalls that cost prior practitioners. The AI never picks a strategy off-the-cuff — it picks from this list, against these rules, against your client's facts.
Self-settled irrevocable trust in a DAPT state (SD, NV, DE, AK, WY+) shielding settlor assets from future creditors after statutory waiting period.
Anchored on: S.D. Codified Laws § 55-16
Gift QSBS to non-grantor trusts before 5-year holding completes; each trust gets its own $10M / 10× basis cap = multiplied exclusion at sale.
Anchored on: 26 U.S.C. § 1202
Avoid the §541 personal holding company surtax (20%) on undistributed PHC income; restructure ownership, income mix, or distribution policy.
Anchored on: 26 U.S.C. § 541
Elect to recognize ordinary income at grant on restricted stock / profits interest; future appreciation taxed at long-term cap-gain rates with holding period running from grant.
Anchored on: 26 U.S.C. § 83(b)
Sell C-corp stock to an ESOP holding ≥ 30% post-sale; reinvest proceeds in qualified replacement property within 12 months; defer 100% of gain.
Anchored on: 26 U.S.C. § 1042
Donor transfers appreciated asset to trust; receives fixed-percentage annual payout for life/term; remainder to charity. Bypass capital gain on contribution.
Anchored on: 26 U.S.C. § 664
Zeroed-out CLAT pays fixed annuity to charity for term; remainder passes to family. Upfront income tax deduction; growth above §7520 escapes transfer tax.
Anchored on: 26 U.S.C. § 170(f)(2)
Contribute appreciated asset to public charity-sponsored DAF; immediate full FMV deduction (within AGI limits); recommend grants over time.
Anchored on: 26 U.S.C. § 170(b)(1)(F)
Donor-controlled 501(c)(3) for multi-generational charitable activity; full FMV deduction subject to lower AGI caps; 5% minimum annual distribution.
Anchored on: 26 U.S.C. § 4940-4945
Donor age 70½+ directs up to $108,000 (2026) annually from IRA directly to qualifying charity; counts toward RMD; excluded from AGI.
Anchored on: 26 U.S.C. § 408(d)(8)
Before US tax residency begins, transfer appreciated assets into foreign non-grantor trust; step up basis on income-producing assets and shelter offshore income from US tax.
Anchored on: 26 U.S.C. § 7701(b)
Elect under §951A(b)(2)(B) and Treas. Reg. §1.951A-2(c)(7) to exclude CFC tested income subject to foreign effective rate > 18.9% from GILTI inclusion.
Anchored on: 26 U.S.C. § 951A
Series of short-term zeroed-out GRATs; each captures growth above the §7520 hurdle without using gift exemption.
Anchored on: 26 U.S.C. § 2702
Pre-funded grantor trust buys appreciating asset from grantor for promissory note at AFR; freezes asset value at note balance.
Anchored on: Rev. Rul. 85-13
At first death, fund a non-marital trust with up to the federal exemption; assets and future appreciation bypass the survivor's estate.
Anchored on: 26 U.S.C. § 2010(c)
Trust qualifying for marital deduction under §2056(b)(7); surviving spouse gets all income for life; decedent controls remainder.
Anchored on: 26 U.S.C. § 2056(b)(7)
Convert traditional IRA → Roth in years of relative low marginal rate; future growth tax-free; eliminates RMDs and 10-year SECURE Act drain.
Anchored on: 26 U.S.C. § 408A
Distribute employer stock from qualified plan in a lump sum; pay ordinary income on basis, defer NUA to sale at long-term cap-gain rate.
Anchored on: 26 U.S.C. § 402(e)(4)
Systematic annual gifts up to §2503(b) per-donee per-year exclusion ($19k/$38k in 2026) — no exemption used.
Anchored on: 26 U.S.C. § 2503(b)
§529(c)(2)(B) election to treat 529 contribution as 5 evenly-spread annual gifts — effectively front-loading 5× annual exclusion per donee.
Anchored on: 26 U.S.C. § 529(c)(2)(B)
Restructure pass-through entity, W-2 wages, and UBIA to maximize 20% QBI deduction; avoid SSTB phase-out where possible.
Anchored on: 26 U.S.C. § 199A
Calibrate S-corp shareholder-employee W-2 wages to a defensible "reasonable comp" floor; remaining profit flows as distributions free of FICA/SE tax.
Anchored on: 26 U.S.C. § 3121(a)
Group activities under Treas. Reg. §1.469-4 so a taxpayer materially participates in the combined activity; releases passive losses against active income.
Anchored on: 26 U.S.C. § 469
Time the fully-taxable disposition of a passive activity to release accumulated suspended losses against ordinary income in a high-rate year.
Anchored on: 26 U.S.C. § 469(g)
Qualify taxpayer (or spouse) as a real-estate professional so rental losses become nonpassive and deductible against ordinary income.
Anchored on: 26 U.S.C. § 469(c)(7)
Operate rental with average customer stay ≤ 7 days so activity is not a "rental" under §1.469-1T(e)(3)(ii); satisfy material participation and deduct losses against ordinary income.
Anchored on: 26 C.F.R. § 1.469-1T(e)(3)(ii)
Defer gain on sale of investment / business real estate by acquiring replacement real property; basis carries over.
Anchored on: 26 U.S.C. § 1031
Engineer-based reclassification of building components into 5/7/15-year property; accelerates depreciation and unlocks bonus depreciation.
Anchored on: 26 U.S.C. § 168
Reinvest capital gain into Qualified Opportunity Fund within 180 days; defer gain to 2026 recognition and step up QOF basis to FMV after 10-year hold.
Anchored on: 26 U.S.C. § 1400Z-2
Spread recognition of gain on sale across years using the installment method; keep capital gain at lower brackets and inside NIIT thresholds.
Anchored on: 26 U.S.C. § 453
Grantor gifts to irrevocable trust for spouse (and descendants); preserves indirect access through spouse while removing growth from both estates.
Anchored on: 26 U.S.C. § 2503(b)
Trust owns life insurance on the grantor; proceeds pass outside the estate and provide liquidity for estate tax / equalization.
Anchored on: 26 U.S.C. § 2042
Transfer residence to trust for fixed term retaining right to occupy; remainder passes to family at discounted gift value.
Anchored on: 26 C.F.R. § 25.2702-5
Holding entity for family investments; non-tax purposes (centralized management, gift facility) supports valuation discounts on transferred interests.
Anchored on: Estate of Strangi v. Commissioner, T.C. Memo 2003-145
Long-term (often perpetual) trust funded with GST exemption allocation; assets compound free of transfer tax across multiple generations.
Anchored on: 26 U.S.C. § 2601 et seq.
Lend to family member at AFR; growth above AFR accrues to borrower without gift treatment.
Anchored on: 26 U.S.C. § 7872
Matcher runs every strategy against your client's facts in < 50ms. Op code: scenario.strategy_match · 400 credits = $4.00 · zero AI tokens consumed.
Every client profile runs through 20 deterministic rules covering AML pattern detection, source-of-funds opacity, OFAC/PEP screening, §2036 retained-interest exposure, basis inconsistency, FBAR/FATCA thresholds, §877A expatriation triggers, beneficiary designation drift, liquidity vs. estate-tax shortfall, stale-plan radar, life-event response gaps, and Form 706 deadline tracking. Each finding cites its primary authority and proposes a recommended action.
AML Beneficial Ownership
Closely-held entities without traced 25% beneficial owners
CTA requires reporting companies to disclose every individual with 25%+ ownership or substantial control. Opaque chains expose the firm.
Trace ownership to natural persons via entity graph (Carta/Pulley/CSV); reconcile against FinCEN BOI filings.
31 U.S.C. § 5336 (Corporate Transparency Act); 31 C.F.R. § 1010.380
AML Source Of Funds
Multiple $250K+ inflows lack counterparty identification
Two or more inflows above $250K with no counterparty captured. KYC and capital-character tax positions both require documented source-of-funds.
Request counterparty documentation, governing instrument, and basis backup for each inflow; record the conclusion in the matter file.
FinCEN Customer Due Diligence Rule, 31 C.F.R. § 1010.230
AML Source Of Funds
Transactions with OFAC-attention jurisdictions in 90-day window
Counterparty traffic with sanctioned or high-risk jurisdictions (RU, IR, KP, SY, CU, VE, MM, BY) inside a 90-day window.
Screen every counterparty against the OFAC SDN list; if a match exists, decline and file SAR per 31 C.F.R. § 1010.320.
31 C.F.R. § 501.603; 31 C.F.R. § 1010.320
AML Structuring
Structured deposits — three+ near-$10K inflows in 30 days
Repeated inflows in the $8,500–$9,999 band within 30 days. 31 U.S.C. § 5324 makes structuring a federal crime regardless of source legitimacy.
Run enhanced source-of-funds diligence; if intent cannot be substantiated, decline and consider SAR obligations under 31 C.F.R. § 1010.320.
31 U.S.C. § 5324; 31 C.F.R. § 1010.314
Compliance Filing Due
Form 706 nine-month filing deadline approaching
Form 706 is due 9 months after death with an automatic 6-month extension on Form 4768; portability-only filings have a 5-year window per Rev. Proc. 2022-32.
Confirm whether a full 706 or portability-only return is required; file Form 4768 if near deadline and engage qualified appraisers.
26 U.S.C. § 6075; Rev. Proc. 2022-32
Data Discrepancy
QuickBooks ledger diverges from self-reported financials
Material variance between pulled QBO trial balance and the client-supplied inventory undermines return positions and matter accuracy.
Reconcile QBO accounts against the inventory line items; document explanations for every material variance.
AICPA SSARS No. 21 § 80 (Compilation Engagements)
Estate 2036 Retained Interest
FLP + advanced age + declining health: §2036 audit magnet
Powell, Bongard, and Strangi show that late-life FLPs with retained enjoyment trigger §2036(a) inclusion of the underlying assets.
Run a Bongard-factor audit on formation purpose and formalities; consider deathbed unwinding if documentation is thin.
Estate of Powell, 148 T.C. 392 (2017); Estate of Bongard, 124 T.C. 95 (2005); 26 U.S.C. § 2036
Estate Beneficiary Drift
Beneficiary designations unreviewed for 24+ months
Designations on retirement, life-insurance, and TOD/POD accounts override the will. Stale forms are the leading cause of unintended distributions.
Pull current beneficiary forms from each custodian, reconcile against the dispositive plan, and update where misaligned.
Kennedy v. Plan Administrator, 555 U.S. 285 (2009); 26 U.S.C. § 401(a)(9)
Estate Concentration Risk
Single asset class exceeds 40% of estate
A single position above 40% of combined NW correlates estate-tax, valuation-discount, and post-mortem liquidity risk into one exposure.
Model concentration drag and discount sensitivity; evaluate CRT, exchange fund, or pre-liquidity GRAT diversification paths.
26 U.S.C. § 2031; Estate of Andrews v. Commissioner, 79 T.C. 938 (1982)
Estate Crummey Failure
ILIT exists — verify Crummey notice paper trail
Annual-exclusion qualification for premium gifts depends on contemporaneous, documented withdrawal notices to current Crummey beneficiaries.
Confirm the trustee keeps an annual notice log with delivery receipts; calendar reminders for each premium funding cycle.
Crummey v. Comm'r, 397 F.2d 82 (9th Cir. 1968); Estate of Cristofani, 97 T.C. 74 (1991)
Estate Idgt Seed Insufficient
IDGT seed gift below the 10% installment-note backing threshold
Sale-to-IDGT structures require enough seed equity (commonly ~10% of note principal) to defeat IRS recharacterization as a retained interest.
Reconfirm seed-to-note ratio; document the bona fide debt analysis under the Karmazin/Dallas framework.
Karmazin v. Commissioner, T.C. Docket No. 2127-03; Rev. Rul. 85-13
Estate Life Event Unresponded
Material life events occurred after last plan review
Death, divorce, business sale, liquidity event, or incapacity after the last plan touch leaves dispositive provisions misaligned with facts.
Open a plan-review matter; update dispositive provisions, trustees, beneficiary designations, and tax projections for each event.
ACTEC Commentaries on MRPC 1.4; Restatement (Third) of Trusts § 50
Estate Liquidity Shortfall
Projected federal estate tax exceeds liquid + insurance coverage
When projected §2001 tax outruns liquid assets plus ILIT proceeds by 20%+, the estate faces forced sale or §6166 deferral need.
Quantify the gap; evaluate ILIT funding, §6166 election eligibility (35% closely-held threshold), or a Graegin loan.
26 U.S.C. § 6166; 26 U.S.C. § 2042
Estate Stale Plan
Plan untouched for 18+ months without a triggering event
Best-practice cadence is 12–18 months or upon material life event. Stale plans accumulate dead trustees, superseded structures, and outdated tax law.
Schedule a full plan review; verify trustees, dispositive intent, and re-run scenario.strategy_match against current facts.
ACTEC Commentaries on MRPC 1.4 (communication); MRPC 1.3 (diligence)
Fiduciary Duty Concern
Client capacity flagged as diminished or incapacitated
Diminished capacity triggers heightened fiduciary obligations. Amendments executed without capacity are vulnerable to contest.
Obtain a contemporaneous physician capacity letter; use neutral video execution and engage conservator or DPOA if not in place.
ABA Model Rule 1.14
State Residency Audit Risk
High-tax-state departure flagged for residency audit
NY, NJ, CA, CT, MA audit departing high-income filers on the 183-day count, permanent-place-of-abode test, and social-tie evidence, reaching back 3–6 years.
Maintain daily day-count evidence; sever vehicle/voter/medical/club ties and avoid maintaining a convenience abode.
N.Y. Tax Law § 605; Gaied v. NY State Tax Appeals Tribunal, 22 N.Y.3d 592 (2014)
Tax Basis Inconsistency
Beneficiary basis reported on return diverges from Form 8971
Under §1014(f) and §6035, a beneficiary cannot claim a basis higher than the value finally determined for estate-tax purposes on Form 8971.
Reconcile beneficiary basis on the 1040/1041 against the issued Form 8971 / Schedule A; correct before filing.
26 U.S.C. § 1014(f); 26 U.S.C. § 6035
Tax Expatriation Trigger
§877A "covered expatriate" thresholds met — exit-tax exposure
Net worth ≥ $2M or average prior-five-year income tax above the indexed threshold trips covered-expatriate status under §877A mark-to-market.
Run the Form 8854 worksheet; evaluate pre-expatriation completed gifts and timing around §6013(g) elections.
26 U.S.C. § 877A; 26 U.S.C. § 2801
Tax FBAR FATCA
Foreign account opened — verify FBAR / Form 8938 obligations
Foreign accounts aggregating over $10K at any point in the year trigger FBAR (FinCEN 114); Form 8938 thresholds are lower for many filers.
Confirm peak aggregate balance, calendar FBAR (Apr 15 + auto Oct 15) and 8938 deadlines, and update the worksheet.
31 C.F.R. § 1010.350; 26 U.S.C. § 6038D
Tax Reportable Transaction
Strategy fingerprint matched against listed-transaction registry
Listed and reportable transactions (e.g., syndicated conservation easements, micro-captives) trigger Form 8886 with severe §6707A penalties.
Cross-check the strategy against the current IRS listed-transaction notices; document any Form 8886 disclosure obligation.
26 U.S.C. § 6707A; Treas. Reg. § 1.6011-4
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risk@2026-05-10
< 100ms
Op codes: risk.run · risk.aml_screen · risk.transaction_pattern — all algorithmic, zero AI tokens consumed.
The semantic state of an authority — active law, superseded, non-precedential, under review — is a first-class signal, not a caveat in a paragraph.
The applicable exclusion amount is $15,000,000, adjusted for inflation after 2026.
Modified by Rev. Rul. 95-58, 1995-2 C.B. 191, on grantor's power to remove and replace trustees.
The grantor's power to substitute the trustee with one related or subordinate to the grantor causes the trust to be a grantor trust under § 674.
PLRs are not precedential authority under § 6110(k)(3). May be relied upon only by the taxpayer to whom issued.
The proposed division of Trust into separate Trust A and Trust B will not cause Trust A or Trust B to lose its grandfathered GST exempt status.
Design partner cohort opens Q3 2026. Three firms locked, two spots remaining. Bring a representative client profile and we'll run the engine against it end-to-end — research memo, matched strategy plan, and risk findings, generated against your facts.