The federal estate tax exemption climbed to $15 million per individual in 2026, or $30 million for a married couple. For most American households, that number ends the estate tax conversation before it starts. For business owners and ultra-high-net-worth families sitting on a company worth tens or hundreds of millions of dollars, it barely dents the exposure.
That gap is where Michael Gold spends most of his time. The Westport, Connecticut, founder and CEO of Gold Family Wealth has spent more than two decades helping entrepreneurs move wealth out of their taxable estates without giving up the seat at the head of the table. One tool he returns to again and again is the Family Limited Partnership, a structure he considers one of the more underused instruments in generational planning.
Consolidating Assets Without Losing the Wheel
An FLP lets a business owner fold investments, business interests or real estate into a single entity. The owner keeps control as General Partner while gifting Limited Partnership interests to children or grandchildren, who receive ownership without a say in how the assets are run. Because those Limited Partner interests carry no control and cannot easily be sold, a qualified appraiser can apply a valuation discount of 20% to 40% when the interests are transferred.
That discount does real work. It lowers the taxable value of what moves to the next generation, trims exposure to estate tax and lets the underlying assets keep compounding outside the estate, all while the founder still runs the show. Gold frames the structure in architectural terms: trusts protect individual assets, he writes, while “the Family Limited Partnership (FLP) is the fortified wall surrounding” the entire estate. It is not, in his telling, a loophole. “The FLP isn’t merely a tax strategy,” he writes. “It’s a philosophy of foresight and discipline.”
A $20 Million Transfer, a $3 Million Tax Save
Michael Gold illustrates the mechanics through a client he calls Dwayne B. in his forthcoming book, “The Goldprint.” Dwayne moved $20 million of company stock into an FLP, keeping a 1% General Partner stake and gifting the remaining 99% as Limited Partner interests to his children. Because those interests lacked control and could not be readily sold, an appraiser applied a 35% valuation discount, which brought the taxable transfer down to $13 million instead of $20 million.
Over the following decade, the business kept growing outside Dwayne’s taxable estate, his authority over the assets never wavered, and his estate tax exposure dropped by nearly $3 million. Because he kept separate books, documented partnership meetings and made distributions that matched the partnership agreement, the arrangement was built to hold up if the IRS ever came looking. Dwayne told Gold afterward: “It’s like I locked the vault and kept the key, while the next generation still benefits.” Gold calls that the real value of the structure: “control without exposure, transfer without surrender.”
Precision Matters More Than the Paperwork Suggests
Gold builds every FLP around three ideas: control, since the founder stays the architect of every decision; protection, since heirs benefit while creditors and litigants cannot reach the partnership’s assets; and leverage, since the valuation discount stretches how much wealth a family can move before the tax bill grows. Combine an FLP with an ongoing gifting plan, Gold writes, and the two together can “preserve as much as $15 to $25 million in wealth that would otherwise be lost to taxes.”
None of that holds up on sloppy paperwork. The Tax Court denied a family’s valuation discounts in late 2025 after finding the decedent had funded the partnership weeks before death and kept effective control of the income, exactly the kind of shortcut the IRS looks for. Gold’s own warning tracks that risk closely: “An FLP’s power is only as strong as its precision.” Skip the separate books, the documented meetings or distributions that match the partnership agreement, and a court can undo the whole structure.
Gold’s firm, Gold Family Wealth, treats the FLP as one piece of a larger governance question, not a standalone tax play. A family’s wealth plan is human before it is technical, the firm argues in its own writing on multigenerational planning, since documents and tax structures only work if the people inheriting them understand what they are stepping into. An FLP transfers the assets. It doesn’t, on its own, prepare the next generation to run them.
Heirs holding Limited Partner interests get a stake in the outcome years before they get the keys, and that early exposure builds the kind of familiarity that keeps a family fortune intact past the founder’s lifetime. From his Westport-based practice, Gold writes that an FLP, done right, becomes “the cornerstone of modern dynastic planning.”
Investment advisory services offered through CWM, LLC, an SEC Registered Investment Advisor.
