Eleanor Whitfield Ramirez , JD

Eleanor practices trusts and estates with a client base that runs from senior tech executives to second-generation families holding legacy equity in public tech companies. Her plans tend to be conservative in structure and aggressive in timing. She pushes clients to use available exemption before it sunsets, and she has spent much of the last three years helping families accelerate gifts of appreciated private stock into grantor trusts while the lifetime exemption still sits at roughly $13.99M per person.

The engagement she runs repeatedly is the pre-liquidity GRAT. A founder holds 14% of a company with a current 409A of $6 per share and internal expectations of a $60 exit inside 24 months. Eleanor structures a two-year zeroed-out GRAT funded with a slice of the founder’s shares, valued today at the 409A with a modest lack-of-marketability discount. If the exit prints at $60, the appreciation over the 7520 hurdle, roughly $300M of gain on a $1M initial contribution, passes to the remainder beneficiaries outside the estate with no gift tax consumed beyond the minimal taxable gift at funding. If the exit misses, the GRAT returns the assets and the client has lost only the structuring cost.

She reviews content on gifting appreciated equity, GRAT mechanics, and estate-level concentration risk.