HNW individual actively engaged in estate planning, irrevocable trusts, gifting strategies, charitable vehicles.
E-02 models the active estate-planning grantor in the years leading to the post-2025 exemption sunset: HNW, mid-60s, structuring SLATs, ILITs, and annual-exclusion gifting against a use-it-or-lose-it deadline. It is the canonical test for trust-account onboarding, Form 709 generation, and grantor-trust income flow-through.
E-02 exists because the federal estate-and-gift-tax landscape is at a known inflection point. The TCJA's doubled lifetime exemption — $13.61M per individual in 2024, projected $13.99M in 2025 — sunsets to roughly half that on January 1, 2026 absent Congressional extension. HNW households who have not yet used their exemption face a finite window to gift assets into irrevocable structures (SLATs, IDGTs, GRATs, CLATs) and lock in the higher exemption against the IRS's anti-clawback regulations under §2010(c)(3). The corpus surfaces households actively engaged in that planning: net-worth median of $10.94M sits squarely in the band where the exemption decision is consequential but the household is not yet in family-office territory. Trust-administration software, fiduciary accounting platforms, and estate-tax-modeling tools all need test data here, and the corpus is calibrated to provide it.
The cash-flow shape is high but variable: median gross income of $372,595, p25–p75 of $248k–$472k. The variability reflects the mix of W-2, K-1 partnership income, trust-distribution income, and qualified-dividend-plus-LTCG that defines HNW grantor households at this tier. Liquid net worth of $4.89M against $10.94M net worth puts roughly 45% of assets in liquid form — high enough to fund a meaningful annual gifting program while still leaving illiquid concentrations (closely-held business, real estate, concentrated public stock) on the balance sheet. All 20 households are homeowners, all 20 file MFJ, and the median age (63) places the cohort in the post-peak-earning, pre-distribution-required-by-RMD window where estate planning is most active.
What distinguishes E-02 from neighbouring HNW archetypes is the grantor posture and the planning-as-action signature. H-02 ($3M–$10M) and H-03 ($10M+) describe the asset profile; E-02 describes the household that is actively transacting on the planning surface — funding SLATs, paying premiums into ILITs, making annual-exclusion gifts, and generating Form 709 reportable events. The 'Legacy / estate' goal on all 20 records, plus the dual-debt-payoff goal pattern (both an active mortgage and a planning-driven secondary debt-payoff target), is the diagnostic signature. This is the household that exercises grantor-trust income flow-through to the personal return under §671, dynasty-trust funding decisions, and the GSTT exemption allocation that estate-tax software must handle correctly.
Aggregated across the 20 E-02 households in the shipped v3 corpus corpus. Numbers describe the corpus, not population claims.
Kevin and Helen sit near the E-02 net-worth median at $10.75M, with $4.84M liquid against $1.7M in liabilities — a meaningful primary mortgage even at this wealth tier, which is the marker of the still-active-planning household. The Legacy / estate goal plus dual debt-payoff goals signal that the planning is in motion: one debt-payoff target is the working mortgage, the other is a planning-driven secondary balance. This is the household that breaks software assuming HNW means debt-free.
Every E-02 household ships with — at minimum — these JSON fields populated. The full schema is documented in the data set you purchase.
Three buyer profiles drive E-02 demand. Estate-planning and trust-administration platforms use the corpus to validate grantor-trust onboarding, Form 709 generation, Crummey-notice workflow, and GST-exemption allocation logic. Tax-software teams working at the HNW tier (advisor-facing tax-planning and high-end professional tax-prep platforms) use it for grantor-trust income flow-through testing, AMT and NIIT interaction, and charitable-deduction stacking under §170(b) limits. RIA and multi-family-office wealth-platforms use the corpus for fiduciary-account onboarding, trustee-vs-beneficiary access controls, and the dollar-magnitudes where bespoke-product gates engage. Insurance carriers underwriting survivorship policies for ILIT funding also test against the corpus's age-and-net-worth combinations.
E-02 is calibrated as the active-planning grantor, not the post-mortem estate-settlement case. Probate, post-mortem QTIP elections, and §6166 deferred-payment installments belong with H-04 (widowed HNW spouse) or as overlays on the relevant H-tier archetype. UHNW grantors with private foundations, direct-investment vehicles, and FLP-aggregated valuations belong in H-03 — E-02 covers the $7M–$15M band where the planning is sophisticated but a single attorney-and-CPA team handles it. Younger grantors (under 50) actively planning ahead of unusual wealth events are P-06 territory until they have established the asset base. State-only estate-tax planning at lower net-worth (e.g., a $3M Massachusetts household worried about state tax) is partially in scope but better tested with an H-01 plus state-overlay rather than E-02. Finally, business-succession planning where the operating company is the dominant asset is closer to P-02 with an estate overlay.
Income, net-worth, and gifting-program shape were anchored during v3 synthesis to IRS SOI Form 706 and Form 709 aggregate data for the relevant filer band, with the SLAT/ILIT prevalence informed by Cerulli affluent-practice benchmarks and ACTEC practitioner surveys on pre-sunset planning activity. State distribution over-weights CA, TX, MA because the planning surface concentrates in high-marginal-state-tax and state-estate-tax jurisdictions. The corpus does not encode specific trust balances as discrete fields — they appear inside the household's investable-asset and liability totals with provenance signaled by the structural notes. Per CLAUDE.md §9, the v3 corpus is frozen and not regenerable; calibration descriptions reflect synthesis intent rather than auditable quantile fits.
H-02 ($3M–$10M HNW) describes the asset profile without the active-grantor-planning posture. Reach for H-02 when the testing question is asset-allocation and accredited-investor gates; reach for E-02 when it is gift-tax, SLAT, and trust-administration flow.
H-03 ($10M+ UHNW) covers private foundations, direct investments, and family-office economics. E-02 is the band where a single attorney-and-CPA team handles the planning rather than a dedicated office.
E-01 is the recipient side of the family timeline. The same household often runs as E-02 in the grantor's lifetime and lands as E-01 in the inheritor's hands a generation later.
P-01 (peak-earner corporate executive) covers the wage-and-equity-comp-driven HNW profile. E-02 starts where peak earning ends — once accumulation is largely done and the focus is transfer, not income generation.
E-02 — Estate Planning Client (Grantor) represents the HNW household actively engaged in irrevocable trust funding, annual-exclusion gifting, and charitable-vehicle planning in the years before the TCJA exemption sunsets at the end of 2025. The corpus is calibrated for trust-administration, gift-tax-return generation, and grantor-trust income flow-through testing.
The TCJA doubled lifetime estate-and-gift exemption (currently around $13.6M per person) drops to roughly half on January 1, 2026 absent Congressional action. Households at $7M–$15M net worth face a finite window to lock in the higher exemption via irrevocable gifts, with IRS anti-clawback regs under §2010(c)(3) protecting the planning if completed before sunset.
Not as discrete fields. The corpus is shaped so that the planning is plausibly in flight — gifting program, liquid-asset shape, age range — without committing to which specific structures any one household holds. Buyers needing structure-typed test data layer that overlay on top.
H-02 describes the asset profile; E-02 describes the active-grantor posture. The overlap is meaningful but the testing surfaces are different — H-02 for asset-allocation and platform-tier gates, E-02 for gift-tax and trust-administration flow.
E-02 is tagged for six bundles — B05, B06, B11, B12, B14, and B24 — covering investment management, goals-and-planning, advanced planning, estate planning, behavioral finance, and values-aligned investing.
No. The shipped v3 corpus is frozen and not regenerable from current code (CLAUDE.md §9). Sampler improvements land in a future v4 release with per-archetype golden fixtures in CI to prevent silent drift.
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