Executive Summary
Irrevocable trusts lie at the heart of a variety of estate planning strategies, as gifts to irrevocable trusts can allow for the transfer of assets outside of an owner’s estate for estate tax purposes with more structure than an outright gift. The downside, however, is that irrevocable trusts are "irrevocable" and can't easily be undone; in moving assets to the trust, the original owner gives up their authority over the assets, with the trustee taking over the management and distribution of the assets according to the trust's instructions. Sometimes, though, the original owner may want to take a 'mulligan' when the assets inside the trust would be more advantageous back inside their estate. Including the power of substitution when establishing the irrevocable trust can provide the opportunity to redo the funding of the trust, without jeopardizing the estate tax benefits that the trust conveys.
In this guest post, Anna Pfaehler, CFP, AEP, a Partner and Wealth Advisor at Constellation Wealth Advisors, discusses how "swap powers" – the ability to exchange assets in an irrevocable trust with other assets of equivalent value – can be used to add flexibility and income tax efficiency to an irrevocable trust.
At a high level, swap powers are often included in trusts because, under the Internal Revenue Code, they turn an irrevocable trust into a Grantor Trust where any income generated by the trust assets is taxed to the grantor (i.e., the assets' original owner). This can be advantageous given the generally higher tax rates imposed on trusts compared to individuals. If the trust is drafted as an Intentionally Defective Grantor Trust (IDGT), the trust's assets are also considered outside of the grantor's estate for estate tax purposes, giving the grantor the best of both worlds when it comes to income and estate taxation.
However, while grantors often include swap powers in their trust provisions to convey Grantor Trust status, many never actually use the swap power for its nominal purpose of exchanging assets within the trust with others of equivalent value. But swap powers can create planning opportunities to take advantage of the differences between types of assets and to optimize the trust's balance sheet as circumstances shift over time.
For example, if an asset within an irrevocable trust has substantially grown in value, that asset will not receive a step-up in basis when the grantor passes away if it remains in the trust, resulting in significant capital gains tax if it is sold later. But if the grantor uses a swap power to exchange the asset for something equivalent in value but with a higher cost basis, they can maximize their benefit from the step-up in basis by keeping the lowest-basis assets on their own balance sheet and the highest-basis assets in the trust. Swap powers can also be used to meet liquidity needs by exchanging more liquid assets in the trust, or to move assets with higher expected growth into the trust to shield their future growth from estate taxation.
The key point is that life goes on even after an irrevocable trust is drafted and funded, and shifting circumstances after the fact can leave grantors wishing for a do-over. And although swap powers won't necessarily solve every potential issue with the irrevocable trust that could arise after the fact – since there needs to actually be property of equivalent value that can be swapped into the trust to use them – it does at least create the flexibility to optimize the trust for whatever the situation at hand may be. Ultimately, advisors can help clients navigate their changing circumstances by recognizing opportunities to re-optimize their financial situation and by making the adjustments (such as a well-executed asset swap) that increase the chances of a better outcome as the client's future unfolds!
My family's typical vacation involves choosing a destination about a month or 2 in advance, looking up a few things to do, and then letting the chips fall where they may. We are light on details because my desire to optimize a vacation tends to lead to decision paralysis. I therefore only make the big, necessary decisions of where to go and how to get there, and then I figure out the rest when I have real-time information about the location, how tired my kids are, the weather, etc. I may have left some vacation-induced happiness on the table, but I have yet to regret a trip.
When advisors steer clients through estate planning, especially if they are new to the process, they often hit decision paralysis. If contemplating death weren't enough, there are dozens of other unknowns that can cause clients to feel overwhelmed. And when it comes to creating a trust, it is easier to coach a client through creating revocable trusts. They can make decisions based on their current fact pattern and have the comfort of knowing that they can simply make changes if they no longer fit in a few years. But with irrevocable trusts, there is a perception of finality. How can they determine what will still be the optimal course decades from now?
Advisors can help clients move past this fear by building elements of flexibility into an irrevocable trust that allows them to maneuver the future when more information is available, thus reducing the likelihood of regret. One of these is the power of substitution. This frequently overlooked piece of trust boilerplate provides tremendous flexibility in irrevocable trusts – if the advisor knows when to use it. A grantor's irrevocable trusts are often mistakenly perceived as final, because of the difficulty (but not impossibility!) of changing them. However, there are still planning opportunities available to the grantor after funding. Like me on vacation, the client might feel locked into the destination after executing the irrevocable trust, but there's still room to re-optimize as they go.
What Is A Swap Power?
Powers of substitution are often included in the boilerplate of an irrevocable trust. Section 675 of the Internal Revenue Code includes several powers that, when given to a grantor, cause the trust to be treated as the grantor's property for income tax purposes. At the very end of the section, tucked under the heading of "General Powers of Administration", is the power to "reacquire the trust corpus by substituting other property of an equivalent value". The grantor, when acting in a nonfiduciary capacity and without the approval of someone in a fiduciary capacity, can use this 'swap power' to remove and replace assets if doing so does not change the value of the trust.
Despite its lack of prominence in the code or a trust document, this power packs a serious punch. Its primary role is to create grantor trust status for irrevocable trusts, which is a key tool in estate tax planning. By leveraging the fact that assets of equivalent value are not necessarily equal, utilizing the power provides additional planning opportunities during the grantor's lifetime. Its inclusion creates the ability to navigate future uncertainty, which is invaluable in trusts that cannot easily be changed.
Creating A Grantor Trust With The Power Of Substitution
An Intentionally Defective Grantor Trust (or IDGT) is a special type of grantor trust for which the grantor is responsible for the income tax liability, but the assets of the trust are outside of the grantor's estate. The power of substitution under IRC Section 675, by its mere inclusion in a trust, extends grantor trust status to the entire trust without any further action by the grantor. The grantor automatically becomes liable for the income tax generated by the assets of the trust, even if the power to substitute is never exercised.
While an exercise of the power can alter the composition of the trust, and therefore its future growth, it does not change the value of the trust or who gets to benefit from the trust. Nor does it alter, amend, or revoke the trust. Because of this, holding or exercising swap powers does not trigger estate tax inclusion under IRC Sections 2036 and 2038 (See: Estate of Anders Jordahl, 65 T.C. 92 (1975); IRS Revenue Ruling 2008-22).
Nerd Note:
If the trust has a beneficiary with an income interest (i.e., all income to Junior while he's living), tread carefully! Swapping producing and nonproducing property could impact their benefit from the trust. Revenue Ruling 2008-22 provided examples where inclusion would still be avoided, and Sam Donaldson in the NAEPC Journal has more on this topic. It is important to always collaborate with a client's attorney before executing a swap.
Grantor Trust Status – The Gift That Keeps On Giving (Without More Gifts!)
Intentionally Defective Grantor Trusts play off the differences in the income tax code and estate tax code. Who owns the trust's assets for income taxes is not who owns the assets for estate taxes, which magnifies the impact of a single gift over time.
The grantor can use their own assets to fund their income tax payments. By paying taxes with personal assets, the grantor further reduces their taxable estate, and the trust's assets can compound tax-free during the grantor's lifetime. Furthermore, the tax payments made by the grantor on behalf of the trust are not considered additional gifts to the trust. Wealth is shifted each year by the payment of income taxes with no annual exclusion or lifetime exemption required. It's the gift that keeps on giving!
But what if this is too effective? Grantors are often concerned about income tax payments becoming too burdensome and impacting their cash flow's ability to support their lifestyle. In this situation, a toggle can be included in the trust to turn off grantor trust status by the grantor renouncing the power. At that point, the trust's tax liability is paid from the trust's assets.
Nerd Note:
Renouncing powers, which would have otherwise caused inclusion, are subject to the 3-year lookback rule under IRC Section 2035. However, the power of substitution does not otherwise trigger estate inclusion, and, therefore, its release should not be subject to the lookback rule.)
Additionally, the tax brackets for trusts are tightly compressed, with the top bracket starting at $15,200 in income for 2024. Because of this, total taxes paid by the grantor and the trust may increase after turning off grantor trust status. Distributions to beneficiaries can shift income to them; however, that may or may not fit with the purpose of the trust. It's important to look at how the trust will be affected by the toggle and the tax-planning opportunities available to the trust before turning off grantor trust status.
Substitution In Action
Many grantors never actually use the power of substitution, but it can be used to remove assets from the trust and replace them with assets of equal value. The grantor and the beneficiaries are in the same economic position immediately before and after the swap because the value of the assets in the trust does not change.
While the IRS might say everything is equal, financial advicers know that 2 assets with the same price tag are not necessarily the same. In fact, advicers often rely on these differences to build diversified portfolios for clients. For example, a $1 million municipal bond portfolio is very different from a $1 million stock portfolio. These portfolios have different risk/return profiles, different income streams, different taxation of those income streams, and different exit opportunities, among other considerations. Today, both would have the same impact on one's estate tax liability, given the equivalent values. However, these values will diverge widely with years of compound growth.
Importantly, such differences between assets create opportunities where having a power of substitution can be handy. Plan as advisors might, they cannot predict the future. As the future unfolds and a client's financial situation changes, the swap power can be used to take a mulligan – that is, the grantor can redo the trust's funding strategy when the assets currently inside the trust would be more advantageous back in their estate. By recognizing these opportunities, advisors can utilize the flexibility in the trust to improve upon past planning by adjusting it for the present fact pattern and deliver a better outcome for clients.
When To Swap Assets
Maximizing Basis Step-Up
A difference in cost basis provides a common opportunity for utilizing the power of substitution in premortem planning. Assets inside an estate receive a step-up in cost basis under IRC Section 1014. Assets outside of the estate do not. A grantor can swap a low-basis asset from a trust back into their estate, moving a higher-basis asset into the trust. Upon death, the low-basis asset receives the basis step-up and can be sold without realizing capital gain. As irrevocable trusts are often funded with assets expected to appreciate substantially, this is a common fact pattern.
If the assets appreciate as anticipated, the trust would have a low-basis asset that would benefit greatly from a basis reset. Furthermore, because the swap would be for an asset with equal value, the appreciation is preserved in the trust and remains outside of the grantor's estate. An asset that will benefit the least from a basis step-up often makes a good replacement asset to be swapped into the trust. The example below shows an asset in an irrevocable trust being swapped with cash, which does not receive a step-up in basis because value always equals basis for cash.
Example 1: Carl, age 85, created an irrevocable trust for his children that included the power of substitution. The trust was funded with shares of a business originally worth $1 million, which have since grown to $10 million. The cost basis is $0.
The business's booming start-up days have passed and its growth is expected to level off. Carl’s children are reaching retirement age and would like to take monthly distributions from the trust for their living expenses. The trustee would like to liquidate the trust's interest in the business, but doing so would leave Carl with a hefty income tax bill: Since Carl is in the top Federal capital gains tax bracket at 20% and subject to Net Investment Income Tax (NIIT) at 3.8%, he would pay $10,000,000 × (20% + 3.8%) = $2,380,000 in Federal income tax if the trust were to sell the business. On top of this, Carl would also need to pay state income tax.
Instead, Carl's financial advisor recommends Carl substitute $10 million of cash, which he intends to bequest to his children and is currently held in his revocable trust, for the shares of the business held in the irrevocable trust. The trustee uses the cash to create an investment portfolio that will provide for the distributions to the beneficiaries, and Carl holds the business shares until his death a few years later.
At Carl's death, the shares of the business were still valued at $10 million and received a full basis step up to fair market value. If Carl’s heirs sell the shares after his death, they would realize $0 in capital gains, saving $2,380,000 in Federal income tax compared to Carl selling the shares while alive. By executing a swap, Carl leaves more assets to his heirs because less of his money went to paying income tax.
Carl's gift of business shares to the trust many years ago had grown from $1 million to $10 million. Because the swapped assets were of equivalent value to the current $10 million value of the business shares, the $9 million of appreciation remains outside of his estate. At a 40% estate tax rate, this gift saved Carl $9,000,000 × 40% = $3,600,000 in Federal estate taxes.
While the example above illustrates how cash can serve as a useful asset to swap into an irrevocable trust, clients often hesitate to part with cash, especially when they may need it for their own expenses. Other assets, such as Income in Respect of a Decedent (IRD) property, also do not receive a step-up in basis and may provide the same basis maximization as cash with less client consternation. Zeroing in on the best replacement requires understanding the client’s balance sheet and how each will be treated for death.
Example 2: Chris made a gift of half of his business to a Spousal Lifetime Access Trust (SLAT), which included a power of substitution, to his wife Nicole. A few years later, Chris decided to sell his business for $20 million to an Employee Stock Ownership Plan (ESOP). The ESOP agreed to pay half the price in cash now and the remainder over the next several years Based on their respective ownership percentages, Chris and the SLAT each received a total of $10 million that consisted of $5 million of the proceeds upfront and $5 million in seller's notes, the payments of which were to be treated as an installment sale. Chris and the SLAT both invested the proceeds in a stock portfolio that qualified as replacement property under IRC Section 1042, which allowed Chris to defer a portion of the gain. Chris' $0 basis in the business carries over to the stocks.
Unfortunately, Chris received a terminal medical diagnosis and came to his advisor to make sure his financial affairs were in order. Chris' advisor suggested substituting the stock portfolio in the SLAT for the $5 million of seller's notes held by Chris personally. Chris’ advisor recognized that because the notes are IRD property, they would not receive a step-up in basis upon his death. Therefore, there would be no income tax benefit to holding the notes in his estate. With his advisor's help, Chris executed the swap, leaving $10 million of low-basis stock in his estate and $10 million of notes in the SLAT.
Upon his death, Chris' stock portfolio received a step-up in basis. Nicole was able to sell the entire portfolio for $0 realized gain. Because Nicole is in the top Federal bracket for capital gains at 20% and subject to NIIT at 3.8%, she saves $10,000,000 × (20% + 3.8%) = $2,380,000 in Federal income tax.
By executing a swap with IRD assets, Chris' estate enjoyed every dollar of basis step-up available.
Giving Efficiently
While the benefit of a trust with swap powers may be apparent during the later years of a grantor's life, death need not be on the horizon for a swap to make sense. In practice, swaps can be used to design planning strategies using certain assets with different cost bases or holding periods that may be more favorable as charitable gifts. For example, if a low-basis asset that would be a prime candidate for donation to a charity is in an irrevocable trust, the swap can be executed to donate it in a more estate-tax-efficient manner than giving it directly from the trust.
If assets from a grantor trust are used to make gifts to charity, the grantor receives the income tax deduction as if the gift were made from their own assets. However, making charitable gifts from one's personal assets is better for estate taxes, as it is another way to spend down the grantor’s estate.
In addition, if the trust were funded using the grantor's lifetime exemption and trust assets were to be distributed to charity, it would be as if the grantor had used their exemption to gift to charity. This portion of the grantor's exemption is effectively wasted, as a donation to charity is not a taxable gift.
Example 3: Rita sold her business this year. Rita and her husband Pete are charitably minded, and now that the business is sold, they want to be more intentional about how their family gives back to their community. Several years ago, Rita created a SLAT for the benefit of Pete, which is invested in a portfolio of mutual funds that have been held for more than 1 year. The trust can make distributions to charity.
Rita and Pete meet with their financial advisor to discuss their charitable goals. They discuss various giving vehicles and determine that a donor-advised fund makes sense for their family as they will be able to take their time in developing a program for their family’s charitable giving without the complexity of running a family foundation. They also decide they would like to make a contribution worth $3 million this year, which would help offset the income tax generated by the sale of the business. As they review their balance sheet, their advisor notes that Rita and Pete have mostly cash from the business sale inside their estate.
Their advisor recommends contributing the mutual funds (currently held in the SLAT created for Pete's benefit) to fund the donor-advised fund. By donating $3 million in mutual funds, not only will Rita and Pete receive a $3 million income tax deduction for the value of the gift, but they will also avoid realizing the embedded capital gain of the mutual funds.
However, giving the mutual funds directly from the SLAT would reduce the trust's value and lessen the effectiveness of the careful estate planning they did a few years ago. Therefore, they choose to swap $3 million in cash from their estate for $3 million in mutual funds from the trust before gifting the mutual funds to charity. After the swap, the value of the trust has not changed, and the mutual funds can be contributed directly from Rita and Pete – not from the SLAT – to the donor-advised fund. The trust can then use the cash to repurchase the mutual funds.
Looking For Liquidity
Differences in asset liquidity can also provide an opportunity for a swap. Grantors often hesitate when funding an irrevocable trust because parting with assets can affect their standard of living. This becomes more pronounced over time as the grantor spends down their personal assets by paying the taxes due on a trust's income. The grantor might find themselves holding illiquid assets, such as a family business or real estate, while the trust contains the liquidity the grantor requires for living expenses. In this case, a swap can be used to solve the grantor's liquidity needs. Swap powers are one of the tools available to move liquidity to where it is needed.
Example 4: Several years ago, Dan and Mary created an irrevocable trust for their 3 adult children for estate tax planning and funded the trust with an interest in a friend's start-up. The start-up recently sold to private equity, and the trust received a handsome payout. Inside their estate, Dan and Mary own a family business, which they intend to ultimately give to their children. Their children work in the business and would like to own it. Dan and Mary also own retirement accounts and real estate related to the business, which provides steady rental income.
As Dan and Mary near retirement, they meet with their financial advisor to discuss business succession, their retirement cash flow needs, and a new financial goal – buying a vacation property. The vacation property will require a slug of liquidity that Dan and Mary don't have, but the trust does.
Upon the recommendation of their advisor, Dan and Mary swap a portion of the business for an equal amount of the cash held in the irrevocable trust. They use the cash to buy the vacation property. The children now own a piece of the business inside the trust, which provides additional liability protection and, if the trust is dynastic, can protect the business from estate tax for generations.
After doing some cash flow planning, Dan and Mary's advisor notes that they'll be able to support their lifestyle with the rental payments from the business real estate, distributions from the remaining business shares, and their retirement assets.
Nerd Note:
The advisor here might also explore selling the business to the trust for a promissory note. Because the trust is a grantor trust, the sale would not cause Dan and Mary to realize a gain. The IRS sees the hypothetical couple as the taxpayer on both sides of the sale, and, therefore, the sale would not be considered a taxable event!
Furthermore, the value of the business would be frozen at the balance of the note, and future appreciation would be in the trust. A sale for a note would be a particularly good choice if Dan and Mary were to require ongoing cash flow from the trust to support their lifestyle. When structuring this transaction, it is important to make sure the trust would be able to support the note payments.
Sometimes it is the trust that needs liquidity and not the grantor. Example 1 reflected such a situation, where the liquidity was needed for funding distributions to beneficiaries. While pre-mortem income tax planning was the driving factor in that example, the trustee wanted liquidity, and the swap allowed for moving cash into the trust where it was needed and the illiquid business back to Carl's ownership.
Shifting Appreciation
Differences in expected returns of assets are yet another source of opportunity for a swap. When recommending how to fund a trust that will be outside of a client's estate, assets with the highest potential for growth should be considered. This allows the (hopefully) outsized appreciation to pass free of estate tax, giving the client more bang for their exemption buck. Given the multi-generational lifespan of most irrevocable trusts, they can often bear the inherent risk that comes with higher expected returns.
Sometimes, these higher-growth assets are only identified or become available after the trust is funded. If assets inside the estate are on a higher-growth trajectory, a swap can move the growth asset, along with its future appreciation, into the trust. It's equally helpful to pull the lower-growth asset back into an estate to slow the compounding of estate tax liability.
Example 5: Charlie, age 70, established a trust for his daughter Dotty and her children. He used all his lifetime exemption and funded the trust with cash, which has since been invested in a portfolio of mutual funds. Dotty, age 40, can receive discretionary distributions from the trust but sees it as her retirement nest egg. She hopes not to use the assets for another 20 years.
Inside Charlie's taxable estate is a minority stake in a business that is spinning off a new tech venture, Newco. Presently, the value of Charlie's interest in Newco is worth $500,000. If Newco performs according to plan, it'll be worth $1,500,000 in 3 years. However, like many other venture investments, there's a chance that it may also go to $0.
Charlie mentions the new venture to his financial advisor. Seeing the growth potential, Charlie's advisor realizes the stake in Newco would increase Charlie's estate tax liability by $400,000 (from $500,000 × 40% tax rate = $200,000 to $1,500,000 × 40% tax rate = $600,000) if it were to perform as expected. After confirming that Charlie won't need the Newco investment to fund his future living expenses, Charlie's advisor recommends swapping Newco with the mutual funds in the trust for Dotty.
After the swap, Charlie's estate holds a diversified portfolio of mutual funds, which is more fitting for the 70-year-old's risk profile and less likely to appreciate and compound his estate tax liability as rapidly as his business interest in Newco (now held in the trust for Dotty's benefit). Given its 20+ year timeline, the trust can tolerate the additional risk. The future appreciation of the asset is now outside of the estate tax system without Charlie needing to use any additional exemption.
Executing A Swap
Differences in the characteristics of assets can create opportunities for swapping, but the execution of the power of substitution requires more than just moving around assets. The ongoing nature of many financial planning relationships may put advisors in the position of recognizing opportunities, but it is always important to check in with the client's estate planning attorney before executing any swap. The specifics of a client's situation and the exact language in the trust matter. Once advisors have the green light from their client's attorney, there are a few other things to keep in mind.
Valuations
The assets must be of equal value, which is not always easy to ascertain. Marketable securities that price daily are among the easiest to swap; however, there are nuances here. For example, stocks and ETFs that trade throughout the day need to be valued with the average price (calculating a simple average is fine) from the day of the swap. As the average price won't be clear until after markets are closed, there's often a need to true up the difference with cash.
Assets without a clear market value (e.g., business interests, real estate, collectibles) will need a professional valuation. Depending on the asset, such a valuation can be costly and may take weeks or months to complete. An advisor may need to weigh the potential income or estate tax savings relative to the cost and extra hassle.
Nerd Note:
Minority or non-voting interests in businesses can receive discounts for lack of marketability and lack of control. This discounted valuation can make a swap of business interest into a trust even more valuable. If there's a liquidity event in which the entire business sells, each owner gets their pro rata share of the proceeds regardless of the marketability and control factors relative to their shares. It's an automatic boost to the value of the stock.
Advisors can prepare clients for the differences between the gift/estate value of their business interests and what they would receive if the business went to market, as valuations of a business vary widely depending on the methodology used to value the business for a specific purpose.
Documenting The Transfers
Executing swaps needs to be properly documented, preferably with statements prepared by the client's estate planning attorney. These typically include the following documents:
- A statement signed by the grantor indicating that they utilized the powers granted to them in the trust document in accordance with Internal Revenue Code Section 675;
- A reference to the power of substitution and its location in the trust document;
- Descriptions of the swapped assets and support for their values; and
- A statement signed by the Trustee that the swapped assets are of equal value.
Advisors may consider filing a gift tax return for their client as a way to document the swap. While not required, this can start the statute of limitations on a challenge to the valuations of the assets. Whether filing a gift tax return is recommended will depend on the facts of the situation and should be discussed with the client's estate planning attorney and accountant.
Other Rules To Follow
Finally, it's worth mentioning that not all property is swappable, and substitutions need to respect other rules and regulations, not just the tax code. For instance, retirement accounts such as IRAs and 401(k) plans cannot be swapped into a trust.
A more complex example is a piece of property with a mortgage. Many banks will not lend to irrevocable trusts (although they are more likely to if the client's bank account balance is large enough). If the property is encumbered with debt, grantors may need to work with the lender before making a swap.
Vacation properties can be tricky, too. If the grantor wants to continue using the property, they'll likely need to pay rent; otherwise, the IRS may determine the grantor never truly gave up ownership of the property and include it in the grantor’s estate at death. Additionally, depending on location, a transfer of title can cause an adjustment to property taxes.
Closely held businesses often have rules around transfers of ownership detailed in the operating agreement. Board approval or agreement from other stakeholders to allow the transfer may be necessary. For newer businesses that may not have encountered this sort of tax planning from their owners before, some education may need to be provided to the shareholders. A grantor trust can hold shares of S Corps, but it's important to make sure that the trust will still be an eligible shareholder after the grantor passes away.
Changing Course
Our most recent family vacation saw us taking our 11-year-old daughter backcountry camping for the first time. It was just one night, but the details needed to be buttoned up. We studied routes, elevation, mileage, water sources, etc., and made our best guess as to the physical exertion her body would be able to handle. When we arrived at our designated campsite, we were welcomed with fresh bear tracks and no place for our tent. Fortunately, we had also underestimated our daughter's strength; she wanted to push on for a mile to another site, which ended up being idyllic and bear-free. While we couldn't abandon the plan entirely at 8 miles in, we could adjust it to optimize for our situation with the new information we had.
Even the best plans need revision. When clients' lives get in the way of their financial plan's original assumptions, the advisor's role is to help clients navigate their dynamic landscapes. The power of substitution creates the flexibility to re-optimize a client's financial situation as it develops by offering an additional income and estate planning tool. While it can't completely undo the decision to create and fund an irrevocable trust, it can allow adjusting for a better outcome for clients as their futures unfold!
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