TRUST & TRANSFER STRUCTURES
Valuation Support for Complex Family Transfers, Trust Planning & Ownership Restructuring
Audit-Defensible • Precedent-Informed • Built on IRS Examination Experience
We provides specialized valuation services supporting complex trust and ownership transfer structures used in estate and gift tax planning for holding companies and closely-held family enterprises.
These engagements involve more than compliance.
They require disciplined economic modeling, conservative discount methodology, and documentation capable of withstanding IRS examination and fiduciary review.
Our practice supports valuation in connection with:
- Inter-generational wealth transfers
- Tiered trust and holding company planning
- Partial-interest gifts and recapitalizations
- Long-term family governance strategies
Why Transfer Structures Require Specialized Valuation
Trust-based and structured transfers introduce valuation risks that do not exist in standard business or real estate appraisals.
These engagements commonly involve:
- Partial interests (5%, 10%, 50%)
- Tiered entity ownership and look-through modeling
- Control and marketability discount sensitivity
- Long-horizon planning assumptions
- IRS scrutiny and penalty exposure
Valuation conclusions directly affect:
- Transfer tax liability
- Audit defensibility
- Sustainability of family planning strategies
This work requires enterprise-level judgment — not formula-driven appraisal.
Transfer Structures We Commonly Support
Our practice regularly supports valuation in connection with the following planning tools:
Grantor Retained Annuity Trusts (GRAT)
Valuation support for:
- Initial funding and recapitalization
- Partial-interest transfers into GRATs
- Tiered holding company contributions
- Discount calibration and sustainability analysis
GRAT valuation requires disciplined modeling of:
- Minority interests
- Control limitations
- Portfolio concentration risk
- Transfer timing and valuation sensitivity
Spousal Lifetime Access Trusts (SLAT)
We support valuation for:
- Founding contributions into SLATs
- Multi-asset holding company transfers
- Inter-spousal planning structures
- Partial interest gifts and sales
SLAT engagements often involve layered entity structures and require careful coordination with trust counsel and tax advisors.
Family Limited Partnerships (FLP) & LLC Recapitalizations
Although formation of new FLPs has declined, legacy and restructuring engagements remain common.
We support:
- FLP and LLC recapitalizations
- Tiered partnership transfers
- Legacy FLP unwind and restructuring
- Successor trust funding
These cases frequently involve:
- Cascading discount analysis
- Control rights modeling
- Look-through valuation
Tiered Trust & Holding Company Structures
We provide valuation for:
- Multi-entity family platforms
- Holding companies with 10+ to 50+ properties
- Layered trust ownership
- Partial redemptions and reorganizations
These engagements require integrated modeling across:
- Real estate assets
- Operating entities
- Partnership economics
- Inter-entity control rights
Minority Interests & Discount Discipline
Transfer valuation almost always hinges on disciplined analysis of:
- Lack of control (DLOC)
- Lack of marketability (DLOM)
- Tiered and cascading discounts
- Concentration and blockage effects
Our discount methodology is:
- Conservative and precedent-informed
- Calibrated to IRS examination experience
- Supported by empirical studies and case law
- Designed to minimize audit volatility
We emphasize defensible outcomes, not aggressive positioning.
Integrated Multidisciplinary Capability
Trust and transfer valuation requires rare cross-disciplinary depth.
US Valuation’s practice is led by a principal holding:
- Accredited Senior Appraiser (ASA)
- Certified Commercial Investment Member (CCIM)
- Master Analyst in Financial Forensics (MAFF)
- Certified Valuation Analyst (CVA)
- Certified General Real Estate Appraiser (CGA – multi-state)**
This allows us to integrate:
- Business valuation economics
- Real estate valuation and portfolio modeling
- Partnership and holding company structures
- Discount and control analysis
- Transfer tax reporting discipline
This capability is uncommon in the marketplace.
How Our Transfer Valuation Is Different
Our work is distinguished by:
- Conservative positioning informed by IRS examinations
- Deep experience with tiered and multi-entity families
- Portfolio-level modeling for holding companies
- Explicit treatment of control, liquidity, and downside risk
- Documentation suitable for fiduciaries, counsel, and examiners
We do not pursue valuation designed to maximize discounts.
We pursue valuation designed to survive scrutiny.
Who We Serve
We regularly work with:
- Family offices and UHNW families
- Multi-property real estate holding companies
- Founders and generational business owners
- Estate planning attorneys
- CPAs and tax advisors
- Trustees and fiduciaries
Begin with a Confidential Consultation
Trust and transfer valuation should begin with independent economic judgment, not predetermined targets.
We invite a confidential consultation to assess:
- Transfer structure complexity
- Discount sensitivity
- Entity layering and control rights
- Audit defensibility requirements
Professional Disclaimer
This webpage and the information presented herein do not constitute legal, tax, or investment advice.
Valuation services are provided solely for appraisal and reporting purposes.
Clients should consult with their legal counsel, tax advisors, and other professional advisors regarding trust structures, estate planning strategies, and tax implications.