Every advisor is aware of the importance of clients making large gift transfers before 2013. Changes to the law are expected, including a reduction in the gift and estate tax exemption amount and a limit of time in which the generation-skipping transfer (GST) tax exemption can be allocated to produce a zero inclusion ratio for a trust. But, what can the descendants of ultra-wealthy parents do in 2012? The answer may be what we’ll call the “split-dollar legacy trust” (SDLT). This technique entails some unusual applications of an insurance plan to potentially achieve valuable planning benefits, which could be lost if this technique isn’t implemented in 2012.