As the IRS turns its attention to trust stacking, the cheap-and-fast structures are the most exposed. TrellaTrusts is the opposite — independent trustees, real legal opinions, and a documented case for every trust.
In 2026, Treasury signaled it is taking a close look at QSBS trust stacking — scrutinizing structures that recycle exclusions without real economic separation, “friendly” trustee arrangements, and last-minute transfers. The exclusion is very much alive. What changed is that defensibility now matters more than speed or price.
Most providers optimize for cheap and fast. We optimize for the one thing that matters when the IRS asks questions: real substance, and the paper to prove it.
Choose from a panel of established, independent Nevada corporate trustees. No house-owned trustee, no conflict.
Trusts drafted and reviewed by attorneys of record, with a should-level tax opinion and genuine privilege behind it.
Non-reciprocal terms, early-transfer discipline, and a documented non-tax purpose for every trust — your defensibility file.
Eligibility attestation, valuations, Form 709, annual returns, and §1045 planning — through your exit and beyond.
We're onboarding a limited first cohort of founders. Tell us about your situation and we'll be in touch with early-access terms.
Thank you. We'll reach out shortly with founding-cohort details and next steps.
Yes. The §1202 exclusion — and multiplying it across separate non-grantor trusts — remains available under current law. Treasury is examining aggressive structures; well-documented, independent, early planning is precisely what stays defensible.
Genuinely independent, named trustees; real legal representation with a written should-level tax opinion; and a documented economic-substance file for every trust. Defensibility is the product, not the fine print.
As early as possible — ideally well before a term sheet, while your share price is low. Waiting until a deal is in sight is the single biggest risk.
No. TrellaTrusts is not a law firm and does not provide legal or tax advice. Your trusts are drafted and reviewed by independent attorneys, and you receive your own counsel of record.
Flat, transparent pricing that includes the independent trustee, legal opinion, qualified valuation, and ongoing reporting. Founding-cohort members receive early-access terms — join the waitlist for details.