Advanced Estate Planning Techniques, with Attorney Andrew Nutbrown

0:03 So, estate planning goes from the basics having just a handwritten will on a piece of paper to very sophisticated documents that account for all kinds of different changes, including limiting the size of the estate to help plan around taxes. I was really excited the other day. I was included on an estate that I'm involved with to meet attorney Andrew Nutbrown with some pretty advanced techniques on how to limit the size of the estate to kind of get through the thread the needle as far as the IRS requirements. Andrew, I think you'll be joining us today.

0:32 Great. Thanks. Thanks for the invitation. So, let's talk about why might somebody want to limit the size of an estate or kind of limit, you know, break into pieces. What are the reasons they might do that and then what are the techniques they use to do that?

0:46 Sure. So, I what I think you're referring to is is the idea and this in the context of the case we were discussing was it was a scenario where we had two young individuals that just inherited a large amount of money and property from their parents. And the in their 30s and the concern, of course, is that at the time when they pass, which could be 40 years from now, the value of their assets it was going to be very large. And that would trigger the estate taxes assuming the laws stay somewhat the same. And that that estate tax could be in the tens of millions or even higher depending on how the assets appreciate over time. And so, part of what we were discussing was the idea of okay, during their lifetimes let's employ some techniques to reduce their taxable estate and get the assets outside of the taxable estate. So, one concept that we talked about were the known as intentionally defective grantor trust.

2:08 And one spouse is going to gift a portion of their assets that they're anticipating would appreciate a lot to a trust for the benefit of the other spouse. when you do that, you have to file a gift tax return and it eats away at your lifetime exclusion amount, which is the total amount of value that you can gift during your lifetime before there's a gift tax for a US citizen or domicile. And then when you pass away through all of the reporting of your lifetime gifts, that reduces the amount of estate tax exemption available for your estate. but the way you gift it to the spouse is you can gift it into a trust where the spouse's interest is limited to an extent that when the spouse passes away, it's not included in her estate. So, the concept is you gift appreciating assets early. the value of those assets grow. When the spouse passes, there's no estate tax.

3:28 And then had those assets not been gifted when the donor, the person who's gifting the assets, passes away, there otherwise would have been a very large estate tax that we got out at a discount. And when you do that strategically, you can use other discounts as well, like minority interests in LLCs, for instance, where the lack of control in that gift reduces the value sometimes of up to 35% or maybe even a bit more than that in some cases. And so, you're maximizing the amount of assets out of their taxable estates. In this scenario, there was enough assets where the clients that are gifting them would not be destitute by doing so. And in these trusts, you can set them up so that for income tax purposes, they're disregarded entities. But for estate tax purposes, they're it's a completed gift. And the value in that is during the lifetime, all of the income tax caused by these assets can be paid from a portion of their estate that's not that's included in their taxable estate. So, over the course of a very long period of time, their taxable estate can be slowly reduced or not grow as much.

5:02 Meanwhile, their portion of their estate that are assets that are not subject to estate tax is growing for that family. And that can be done for the kids, it can be done for a spouse. And that's often what we're employing or at least is in involved in a comprehensive plan for families where they have a great deal of wealth and they're concerned about the estate tax consequences many years down the line. right now, we've got very high estate tax exclusion amounts. So, the other thing is if governments change and the estate tax exclusion drops to like let's say 5 million if there's a different government in 10 years, then you're not penalized for using the your exemption when it's high. So, that's the other benefit, too.

5:57 What's What's ironic about this case is on one hand, here we are using very sophisticated estate planning techniques for the children, yet the father, which started this whole process, passed with an estate plan that he paid for. This is such a classic case as a real estate agent, this is classic. The customer has an estate plan in a binder, it's beautiful, tabs, and all kinds of papers, all kinds of stuff, but it was never executed or funded. And so, this is a class This is both ends of the deal. If you don't plan, what happens? And it was a mess, and I got involved with a team to help take this mess of property and bank account assets and the and the money was at a bank, First Republic, that went bank that went out of business, and so they were holding up the cash we needed for the business, and the business that had to be run, all this without an estate plan, and then now we have a chance to I think maybe after the fact correct things for next generations by using these sophisticated estate plans. And it's almost like this is the before and after picture, it's the same family down the road. So, let's talk a bit about this. You know, again, I just find it funny to have you called in on this one because of that reason. when typically do you get involved in the estate plan? My sense is that people don't come up with these ideas on their own. They just know they have a problem.

7:20 My guess is that you probably service or work with other estate planners and come in maybe as a consultant to add some of these special techniques, or is this kind of a routine estate planning process for you?

7:32 Well, we again, we take a very different approach depending on the on the client and their needs, right? definitely our firm's been reached out to even by other estate plan planners where they you see better recognizes that there will be an issue, but might not be too familiar with these types of techniques to really implement it. so that that okay occasionally happens. the cuz you can get really creative and that's honestly what attracted me to this field is it gets really interesting sometimes because you can loan you can do loans, you can do transactions with these trusts. And that's a that's an opportunity because they're disregarded for income tax purposes. So, any interest on those loans or don't really cause any income tax concerns. And you can even convert them if situations change from a disregarded entity to a separate taxable entity. Sometimes there's a reason rationale for doing that. And yeah, so most of our clients that we end up engaging it often they know that there's going to be some sort of tax issue, but they might not be too familiar with the intricacies of it.

8:59 And then often our approach is because there's a whole plethora of different options that you can employ, we'll we'll work to give them a few different proposals and how to for like a like a full plan involving these types of trusts. And then they'll pick one of let's say three or four options and then after a long conversation we get what their even sometimes their non-tax goals are and then we try to address and accommodate that. so it ends up it's not like someone comes in and say, "I want one of these intentionally defective grantor trusts." It's normally there's an estate tax issue or we're just doing the normal estate planning. They might not realize that that would be very useful in their situation, and then we raise that issue with them and then we go from there.

9:56 And you talk about a lot of money. I mean, on a larger estate, you know, a $10 million difference of assets at 10% is a million dollars. And while I hope you get really good fees, I don't imagine you're getting a million dollars on an estate plan, but the customer that's real savings, money in their pocket. It was just a 10% and the tax rate's probably higher than that. and Or you talk Yeah, 40%. So, you're talking about, you know, a $10 million differential $4 million in a million-dollar estate, you're talking about $400,000 or $400,000 a million-dollar just in this one defect one tool. At 40%, you're talking about $400,000. And so, these are important issues that require sophisticated planning. And while it's nice to have an attorney that you know and familiar with, it's important to take a look at some of these advanced techniques as a way to save some additional money. So, obviously, look, I love talking about this. I was fortunate that in my case the customer invited me to join in and sit down in the meeting and I was like my And I And I have [The Estate Planning Podcast] as a podcast. I mean, I'm pretty familiar with the basics of these topics. And my mouth dropped when I heard what you're doing. And it makes sense. It's It's like logically, it makes sense. And we're literally discussing today in the news lowering the exemption on the state plan. I don't know whether it gets approved or not. Who Nobody has a crystal ball, but it's certainly a topic that customers in this space are and should be concerned with. And I was just shocked at you know, what you had to offer. And at the same time, it's logical. It makes sense. It's not like it's a you know, putting money in the Bahamas and lying about it. It's This is a way to structure money and who has it and who doesn't have it and putting it where it does not get taxed until it's the right time. So,

11:43 Yeah, the and so sometimes there's a disadvantage putting these assets in trust, too, because when sometimes like so, this is a very hot topic, especially last year. or the last couple years because even right now under the current law in force now as of January 1st, 2026, the applicable exclusion amount, like the amount that dictates that estate tax exemption is supposed to drop to around 7 million. Now, most people think that's not going to occur given what's going through Congress now, but who knows?

12:28 Who knows? Yeah. Who knows? I mean, you can say that, but really until the law's If you don't If nothing happens, that's going to happen, right? If nobody changes If there's no law passed, unless the unless majority of senators, House agree, and the president signs something, it's it's a fact that they will drop to that number.

12:49 Yeah, and that's obviously gives a lot of people concern where their they would already have estate tax exposure because that's the difference between a married couple of having a combined roughly 28 million dollars of exclusion to a combined roughly 14 million dollars of exclusion. So, that's a huge difference. And so, there was a tendency to think, "Okay, let's do these types of transactions now while the exclusion is high before it drops so you don't get that estate tax burden." but when you do that, so the benefit of putting it in these trusts is, okay, these assets will not be subject to estate tax when the spouse passes or the kid passes, and when the person who's giving the assets pass. But, normally what happens when someone passes away, there's a in the US there's a step up in capital gains basis. So, there's no So, you might have a real property, for instance, that has a basis of $100,000 when it was purchased a long time ago, and there's there was depreciation taken on it. And, it's now worth $2 million, let's say.

14:08 And, if you pass away, and the person owns that property at the date of passing, the basis is now $2 million, and if it's sold the day after, there's no capital gains. If it's held in this type of trust, and it's a completed gift, which is great for estate tax, but the basis is not stepped up. It's it's whatever your basis was when you when you gave it. So, it's $100,000. And, so then that that's where you have to counter balance. And, one of the benefits of these types of trusts that they're known as IDGTs, the intentionally defective grantor trusts, are that it's because it's disregarded for income tax purposes, and the types of powers that you can keep as the settlor, the person who created the trust, is you can swap the assets. So, you could you can transact or sell assets to this trust that have a high basis in exchange for assets for a low basis, so that ideally when you pass away in your taxable estate are all assets that get the best impact for the step up in capital gains.

15:33 And the assets that are outside has less of an impact in capital gains. So, art artwork sometimes is a good example. or really collectible like often those items can have a huge disparity in what the basis is in the asset versus And so really you just want to inflate your estate with low basis assets at the time of passing. But, there could be some nightmare scenarios where someone gifted all of these assets into these trusts thinking the exclusion that was going to go down. And then it doesn't and then they pass away. There might not have been a significant estate tax issue anyways and they just lost all of the step up in basis. So, leading up to that we were a lot of lawyers in this area were calling it sunset planning because of the end of that high exemption that was originally thought to occur and still is January 1st, 2026. there are risks associated with put putting them putting all of the assets in. So, you have to wait.

16:55 Yeah, and the thing is there's obviously risks with anything and anything that you know it's powerful you know it can cut both ways. and I think also you know one of the challenges a very common problem with estate planning is families have an asset that they would like to keep, but if that's by far the biggest asset in the family that's it might create tax liability or if you want to distribute it, creates problems in how you distribute the property. You know, famously now the Lakers are being sold. Why? Because you had three siblings and they all wanted some of the money and they all wanted some of the control. And the problem is you can't effectively sell and run a third I guess it depends on the business and such. But in many cases, businesses get sold because they need to pay taxes and the only asset to pay that might be the business being where you know with exclusion is and what kind of trust it's in and so on. And unfortunately, when you have to sell something, you don't get as good a price as when you want to sell something. And so that's another strategy. This is what is the asset and how timely is it because there's different times of markets that make sense as other times of markets that are difficult to sell and you don't want to have to sell something that you don't want to. So obviously again, these are sophisticated. Now I imagine that you must have a lot of clients watching July 4th. I think the date kind of that seems to be in the news on when this bill should be passed. They're targeting to July 4th and you have from then until January. So you have about a 6-month period where it's passed, let's re-evaluate or if it's not passed yet, maybe we need to start thinking about what our options are. So what does that look like for you between July I mean right now here we are in late June and according to this episode is going to come out in about 8 weeks or it's going to come out around August. But have you thought about what July and August look like? Let's imagine that it's not passed. I would imagine every client you have should at least look at their estate and say, what's this changing it do to me and what changes can I make now before those

18:57 Changes go into effect? so this was a big focus especially after election night last year. almost immediately. I was actually at a tax conference on election night and some of the topics the next day shift shifted because originally they were focused on the sunset planning then there's a lot of clarity. And so if the type of techniques that we were that Kevin Moore, my partner and I discussed were a few different options. One was because again you don't want to gift all these assets necessarily especially if your client's very elderly and there's not there might not be that much appreciation. and end up losing all of the tax bases. The hardest and the hardest type of family to plan for really is in this range where they might not hit any estate tax if the exclusion amount stays high but if it goes down that they could.

20:20 Because that'd be such a big percentage of their assets, right? Theoretically if you were go from 14 to 7 that's like a 50% all of a sudden exposed to taxable consequences.

20:28 Yeah, so if you're like a family at 20 million in total would be a good example. And the loss in the step up like you could set up all these assets in these trusts the family might still be very comfortable setting that up but the law there wouldn't have been an estate tax anyways perhaps depending on their age and what type of assets they were they had. And then you just lost all of the cap capital gains benefits of the step up. So some things that we were doing were one option was to have all of the trusts set up all of the entities set up in advance. And pre-scheduled in December of 2025 that it looks like it's actually going to sunset, then that's when they sign the assignments to transfer over the LLCs or whatever assets that are being targeted to get it out of their estate before the sunset comes into force beginning of January. So, that was one option. second option was to prepare the trust fund it and create the trust mid-year this year or a little late this year and have a provision where the primary beneficiary has a disclaimer power and so there's a qualified disclaimer under that IRS code provisions.

22:10 That if you disclaim within 9 months, you can there won't be any like you can disclaim within 9 months without adverse tax consequences. So, if you do the disclaimer, you would have 9 months. So, if you funded it in August, for instance, you could you could execute that disclaimer and undo that that gift in early 2026 after you would have clarity. And then the third option, and this is specific to spouses, is you could incorporate provisions in the trust that would otherwise be a gift to the spouse. But you could allow the trustee to make a QTIP election. So that it's it qualifies for the marital deduction. When you do that, it's included in the spouse's estate. Now, the provisions would require that the spouse receives all of the net income and whatnot. So, you have to make sure and be careful on the terms. The trust would have to be able to qualify for it. So, we called it a Q-tippable trust. And that you wouldn't have to make that election until the gift tax return is due.

23:30 Which if the gift was made this year at any time in the year, the ultimate deadline for making that election would be October 15th, 2026. So, that's well into the following year. So, those were some of the options that and techniques that were being considered to try to address the risks associated with the loss in basis with an unclear exclusion amount at play. The On oddly enough, it was easier to do this planning for a family with a lot more assets because then it's clear get the appreciation out of the estate. And there's less concerns about the loss. Of course, the basis planning is always important. But there's also less concern about the ability of your own clients to make sure that they have all of the assets available to be comfortable and you're not you're not giving too much out outside of their direct control.

24:40 I think in this estate case I met you in, you were kind of brought in as a I don't want to say second opinion, it was really more a second go at it because we had somebody else who just wasn't able to give clarity and it just kind of exceeded their abilities. and like I said, the actual estate that has been passed is a probate estate. Now we're dealing with the estate we're now working with you is the heirs who will receive the money and put it in the estate. But imagine you must come in and kind of look at other people's work and try to reconfigure what's been done or change what's been done. Is that a big part of your business is coming in where something's been done and there's some outstanding issues or potential issues?

25:25 Yeah, no that happens. The best case scenario is when the trusts are still revocable and you still have that ability to completely change whatever is set up if for whatever reason there's an issue or you know, in fairness to the drafting lawyer it could have been drafted a long time ago and these techniques might have been or certain techniques might have been less common. but yeah, like I've I see it at every end. The part where it's just a simple estate plan at the beginning like okay, we've got all of these options. It's very easy to update an estate plan especially that's just a revocable trust or a will or something like that. I see it often where we do a lot of trust administration work so the implementation of these trusts after someone passes. or an irrevocable trust that that's a gift that's a little less common but or we're advising trustees and so often times when the first spouse passes for instance a lot of a lot of these trusts are severed into sub trusts and a portion of the trust might be irrevocable. often depending on how that irrevocable portion sub trust is drafted there might be a power of appointment right?

26:51 Which is basically an ability or a power granted to the beneficiary. This scenario would be the surviving spouse that can change the default remainder beneficiaries after their passing. And you could have a general power of appointment which means they could give it to anyone including themselves. the consequences of that is if when you have a general power of appointment like that all of the assets are included in your taxable the surviving spouse's taxable estate. Sometimes a bad thing, sometimes a good thing because you want that step up. or a limited power of appointment where there's some restrictions. You can only appoint it to certain types of people. and they and they can be very broad like anyone except yourself for instance or your estate or your creditors would be a limited power of appointment. Or the creditors of your estate. And so that's often a viable option. I've done that for clients where in the process of determining, "Okay, this is what we're going to put in trust A. This is what we're going to be in trust B put in trust B. Also, you have a power of appointment right? Let's amend this trust so that it can or exercise your power of appointment right so that the generation skipping tax exclusion is more efficiently used. The so for example we had a trust where after the passing of the second spouse everything goes directly to the kids.

28:29 That sounds great, but then that means it's included in the kids estate. And otherwise you could have had it where it's outside of their of the kids taxable estates and the grandkids taxable estates and so on and so forth so that these assets can pass down to each successive generation without estate tax. And there's also a generation skipping tax that can apply. but usually the way these trusts are allocated is that the first spouse's exclusion can eliminate the estate tax and the potential generation skipping tax that would apply to the grandkids and great-grandkids. And then I Often you might not even have those powers and just like last week we had a hearing on a petition that a court petition we filed to modify the trust to give that spouse a limited power of appointment right. and at that point you just see what tools you have in your toolbox. Can you amend it? If you can, great, that's easy. Can you exercise a power of appointment right? That's also pretty easy to do. And you're just operating under the confines of that document.

29:50 If that can't be done is there a way that the trust can be decanted? Which is basically a way of modifying an a trust or an irrevocable trust without having to go to court. In California, that's very rare that it would be sufficient cuz you're you're very limited in what you can do, but in other states it's more broad. And finally, if none of that is an option, can you go to court and go and get a court modification of the trust? There's a lot of case law actually in IRS rulings recently that evaluate court mod- modifications. So, you also have to evaluate what are the tax consequences of that modification. You could modify a trust, for instance, and to avoid one issue and the IRS will take a position, okay, that change is actually a gift and then trigger a gift tax unexpectedly.

30:49 Ouch. All these types of things you have to evaluate, but definitely, I see it on the trust administration side the most at every single stage when everyone's alive, the when one spouse has passed, or when it's down to the kids and you know, you get different scenarios. A kid moves to a different country where they're going to be taxed differently and what might have made sense in the US does not make sense in that country, so you want to change how it operates. So, that's that's what our firm kind of does and evaluates things as we go along in assisting the family, which often the goal is we're getting the assets down to the heirs, but what's the best way to do that? The most efficient way to do that.

31:38 Do you I know in the case I'm working on with you, we have a fiduciary who has brought you in and then brought you in to do the estate planning for the beneficiaries in this case. You mentioned trust administration, does your firm do in some cases trust administration, or do you rely on other parties as fiduciaries to do it for you?

31:57 So, we represent trustees often and then guide them in that. Got it. sometimes it's a professional fiduciary. other times it's a lay person. People appoint their family members as trustees all the time. So, that's what I mean by trust administration work. It's us representing the trustee usually. And sometimes it's the trustee is the beneficiary. In the case of a surviving spouse, that's often the case. And so, we're wearing two hats in a way.

32:28 One of the challenges that I'm sure you must see is that and I see this as when consumers choose an attorney, you know, there's a balance between technical knowledge, which is hard for the consumer to appreciate, and the relationship, which they can appreciate better than anybody because they have a relationship with somebody. And I just find they often fall to the relationship, which often gets them an attorney who is not suited for this kind of work. The modest ones realize, "Okay, I can help you with this part of the job, but I need to bring somebody else in to help us with this specialty." I find too often attorneys don't do that. They try to take on too much themselves, and as result, create problems, unintended problems, or don't anticipate what could be a major problem. And obviously, we're talking about some very sophisticated things, anticipating law that hasn't been passed yet, or may not be passed. So, who really knows, you know, you can't even guess at this point what to do. But, you know, what's your best advice when a consumer evaluates that? Obviously, if they haven't met you personally, if they haven't met your firm, you know, it's hard to say, "Oh, what you're saying this guy said was wrong" makes sense to me because there's maybe a long relationship with that attorney who represented them on their business or some other, you know, civil matter, and they're neighbors, they're friends, they're church members, but they don't know what you're doing. And I just find too often that attorney just doesn't defer in the area they don't really know. So, what would your Obviously, you can't say that to a to the client because they're represented. We can use this podcast. What would you say or what would you recommend me to say to the customer and say, "You really should get another opinion because I just think that attorney is a little out of his league on the this sophisticated topic."

34:09 That's, you know, that's really difficult issue because I think it's very difficult for any area of law, honestly, for a client to really, you know, whether their attorney is exceptional or terrible. Right? and like honestly, I tell clients sometimes I like if you if you're know all of these things and can then you might be a crazy person or a nerd like I am, right? So, the it's just very difficult position to know whether you're from the consumer's perspective to know whether your attorney is is exceptional or not. You can you could be getting terrible advice. It could be said very confidently and that can be very convincing.

34:59 Right. If I had a physician operating on I don't know. At my knee or I don't I don't really know anything about how a knee works. And they could be saying you need this surgery. There's another and that might be very bad advice cuz it might be a less invasive way of dealing with it. I think it's kind of the same. from the attorney's perspective, like really in my view, there's a professional duty and an ethical duty to refer out work that you're not capable of doing. and but I don't know whether that's exercised or employed as often as it should be.

35:54 You know, I look back at my career, I'm a little older than you. Without exception, the people who did the best I think it's just good business because the people who did the best in the business were hyper-focused and as a result became experts, can work on the most expensive piece of value for the customer and charge the fee appropriate for that expertise and avoid all the other things that they don't do at that exceptional level because why would you work at an average pace where you can work on exceptional material? And I just in every field, I whether it be doctors to use your example or attorneys or I'm in real estate I think same thing there I could sell kinds of properties I really focus on one area because I'm more viable when I stay in my lane than any other realtor. I'm only an average agent when I talk about just a general open house.

36:42 I actually do have a thought. The best lawyers in my view that I have worked with and against in litigation cases are ones that will say they don't know something when they don't know something.

36:56 Yeah. If your attorney is saying oh I know everything well and that that can be maybe a bit of a red flag at times.

37:07 Yeah. Yeah again like the most competent counsel in my view they will say what they know and they will say what they don't know or they say that they'll have to research the issue and then get back to them. that's normally some someone that's might even be humble or might be a good personality trait but also in my experience and I'm I might be biased I see I've often found that they are the most capable as well.

37:38 You know not hiding behind a front. I always say I it's something about law school that attorneys are generally really good at sounding like they know what they're talking about when they know nothing about what they're talking about. you see that in court when they're on their feet and yet I guess in the case that I'm I'm I'm meeting with you this is a case of an attorney who I know him to be very humble. He brought in that probate specialist. He brought in your case to work with the estate. He was I think he knows enough about his practice. He has a great relationship with the client. Great relationship with the general counsel work that we that he does because he has his relationships with the decedent in this case the father. But to bring in experts to really give really good service to customer I think is important and that's the challenge for all of professionals is I think find that area that you excel at, try to put as much time as you can in that, and then try to stay out of the rest and let experts handle that as well. So, I

38:33 I think it's even a good business decision, honestly, because in the long term people will well, respect you more, but also they'll they'll trust you, too. So.

38:45 Yeah. 100% I feel same way. And as a result, I just want to say I've gone a little long here with the time cuz I just find your material so fascinating and I think so important. Not so much that I understand the material, but I understand there's a lot that I don't know, and that this world is really changing very quickly. So, Andrew, I know we spoke before privately as well as on a on a video. I just really appreciate your willingness to educate and to help out. just for anybody who's interested in reaching out to him, particularly if you're an attorney who's but you know has a particular case, there's his phone number for the law firm, the email, and the website as well to get more information about him. and if you have a contact point as well. Andrew, I just can't thank you enough. Thank you so much for both for the work you do for Oops. the work that you do for our client and the time you spent here today teaching all my platform.

39:33 No, not a problem, Bill. Thanks for having me join. And I don't know. It's it's fun talking about this stuff for me. So.

39:42 I want to circle back to you sometime in August when the either this new bill's passed or not passed, and but my guess is you'll be so busy trying to figure out what to do at that point. I mean, I don't know if I can hold of you. So, I'll do my best to reach out to you then and see what's going on, okay?

39:53 Hopefully we just have certainty. The uncertainty is going to make it a lot more busy on our Is Is it just cuz the uncertainty creates more business for you? Yeah, it's just not settling, and I think that shows your commitment to helping your customer, right? You are there to help the customers get certainty, and you'll figure out something else to do at that point. This uncertainty, I do think is creating a lot of stress for people. it's not productive.

40:14 The concern is that it'll get too close. Honestly, it's already really close if the sunset occurs and then I'll go down a huge tangent but in California in particular, it's very hard to do some of this planning because of community property laws. Normally, we you want to gift it as your separate property for various reasons and there might not be enough time to really implement things properly and there's a lot of risks where like the classic example is one spouse gifts into trust to the other spouse and then that spouse does the exact same thing. The trusts look identical. That's a classic great way to have all of those gifts disputed and overturned by an IRS challenge. So Yeah, we'll see how things go.

41:09 Very exciting. Well, Andrew, thank you so much again. Really appreciate your time. Yeah, thank you. Thank you. And for the rest of you this is Bill Gross, we do estate planning every week where we interview most commonly estate planning attorneys but also other vendors to learn how to be more effective at serving our customers whether real estate agent or a non-estate planning attorney, we want to give great service to our customers by using the best professionals. And just to wrap on something that Andrew said which is, you know, customers get so much more from the best professionals they do from the average. We always make sure we work with them. So hopefully we've interviewed one today, Andrew on estate planning. I'm Bill Gross. If I can help any way at Bill Gross Probate, if you like this, please like it, put a comment in. If you want to be interviewed or know somebody should be interviewed, send that along as well, put a comment in, subscribe and as always, make today your best day ever. Thanks so much.