Estate tax if you hold and pay$23.6M
Best planHold + ILIT, premiums from cash
Heirs gain vs hold and pay+$11.3M
Strong case in this model: wins in 99% of lifetimes
| Plan | Heirs keep | vs hold and pay | Estate tax |
|---|
| What each path earns a year, after tax | Per year | Inside the taxable estate? |
|---|
Does it still win if death comes early or late?
| If death comes at | Odds it has happened by then | Best plan vs hold and pay | Premiums paid |
|---|
How it scores: what your heirs keep after income tax, estate tax (federal and state) and debt, plus any life insurance death benefit held by an irrevocable life insurance trust (ILIT). The federal exemption is $15,000,000 per person in 2026 (P.L. 119-21), indexed by chained CPI from 2027 (about $15,460,000), then 2.5% a year; married couples use portability. Policy prices are estimates from published carrier rates and October 2026 carrier illustrations for a no-lapse universal life policy, not a quote; final pricing needs underwriting. Suspended losses are freed only by a fully taxable sale of the whole activity (IRC 469(g)) and are mostly lost at death. Notes over $5,000,000 carry the Section 453A interest charge. Policy prices for 10, 15 and 20 year pay are scaled estimates; lifetime pay is the published-rate basis. The note is a fixed 6% stream, not an index fund, with no allowance for the credit risk of the buyer or insurer behind it, liquidity or fees. A note still owed at death is income in respect of a decedent: no step-up, and the heirs owe the income tax on the deferred gain. The 2027 figure is our estimate (IRS not yet published). Results are projections, not promises; a death benefit depends on premiums being paid and the insurer's ability to pay. Hans Goldstein is an Enrolled Agent and a licensed life insurance agent (CA #4273294) who may earn a commission on a policy; he is not licensed to sell securities and does not recommend investments. Education only, not tax, legal, investment or insurance advice.