Attorney Larry Kline frequently handles very complex and sophisticated estate planning needs for his clients. For example, he crafted the estate plans of two brothers, who, with their wives, co-owned two companies. Larry restructured both companies so that the brothers and/or their wives held all of the voting shares. Then the ownership was further restructured so the two companies became separately owned by the two couples. Each couple then sold the non-voting shares − representing 99 percent of the equity in each company − to trusts for their children. In this instance Larry used a technique known as an “intentionally defective grantor trust,” which has many advantages. This technique reduced or eliminated the capital gains tax. It also ensured that the trust income was taxed to the parents, not the children, which is a very effective way to make gifts to the children without using up transfer tax exemptions. The technique also allowed the sale of shares on favorable terms and thus further minimized the transfer tax exemption. In addition, it utilized a strategy that effectively used generation-skipping exemption to permanently shelter the value of the companies from transfer taxes. Following the sale to the children, the child in each family wishing to own and manage the respective companies was able to use a similar technique to buy out their siblings and acquire the voting shares, utilizing the trust structure.