Community Leadership

• Desert Botanical Garden: Planned Giving Committee
• Ballet Arizona: Planned Giving Committee
• Phoenix Zoo: Planned Giving Advisory Committee
• Arizona Community Foundation (ACF): Planned Giving Advisory Committee
• Central Arizona Estate Planning Council: Executive Board
• Phoenix Rescue Mission: Professional Advisory Committee
• A New Leaf: Planned Giving Advisory Committee
• Valley of the Sun United Way: Legacy Society

Professional Background

Before Jonathon and his wife relocated to his hometown of Phoenix in 2015 to raise their children, he practiced with two of the premier estate planning law firms in Silicon Valley – most notably, the personal tax planning group associated with the preeminent venture capital law firm Wilson Sonsini, which led IPOs for virtually every major Silicon Valley-based company, including Apple, Google, Amazon, Tesla, Twitter, LinkedIn, Netflix, Pandora, and GoDaddy. As one of the top tax-planning technicians in Silicon Valley, Jonathon designed, drafted and implemented estate plans for hundreds of the wealthiest individuals in the world, including founders, C-level executives, “Midas List” venture capitalists, and angel investors associated with the world’s most prominent tech companies.

Equipped with sophisticated tax and estate planning knowledge that is unique to the Arizona legal community, Jonathon quickly distinguished himself after his return to the Valley as one of the Phoenix area’s premier tax and estate planners.

Jonathon has personally architected and implemented over 500 tax planning transactions using one or more of the following advanced planning strategies:

• Optimized Gift Trust (OGT)
• Generation-skipping dynasty trusts (GST trusts)
• Charitable remainder trusts (CRTs)
• Charitable lead trusts (CLATs)
• Spousal life access trusts (SLATs)
• Family limited partnerships (FLPs)
• Sales to intentionally defective grantor trusts (IDGTs)
• Grantor retained annuity trusts (GRATs)
• Irrevocable life insurance trusts (ILITs)
• Qualified personal residence trusts (QPRTs)
• Nevada incomplete non-grantor trusts (NING trusts)
• Asset protection trusts (APTs), self-settled and non-self-settled
• 678 Trusts, Beneficiary Defective Inheritors Trusts (BDITs), and “MegaTrusts” (limited to review, analysis and administration; not creation)

Representative clients include:

• Founders, executives, and owners of private and public companies
• Private equity, venture capitalists, angel investors and entrepreneurs
• Developers, syndicators and real estate investors
• Professional athletes
• Physicians, attorneys, accountants, executives, and other professionals
• Philanthropists

Legal Services in Detail

Estate Planning

• The cornerstone of most estate plans consists of a revocable living trust, will, durable power of attorney, and advanced health care directives. By helping clients put these documents in place, Jonathon helps protect assets, avoid probate and undue delay, and minimize hassle and potential litigation after death.

Enhanced Gift and Estate Tax Planning – “Optimized Gift Trust”

• The Optimized Gift Trust is a turnkey solution that was published in the national Estate Planning Journal by developer Jonathon Morrison.  The OGT is designed for wealthy individuals who wish to reduce (and, in many cases, eliminate) their federal estate tax by making large gifts out of their estate, but retain maximum access, control, protection, and use of the assets while they are living (within IRS limits). There is special urgency to fund the OGT since record high federal gift and estate tax exemptions ($13.61M/$27.22M) can be locked-in, but only if the OGT is funded before the exemptions expire (“sunset”) on January 1, 2026.

Charitable and Philanthropic Giving

• The greatest joy in Jonathon’s practice is helping clients who have philanthropic goals and are willing to ask, “How much is enough?” As a frequent speaker on creative charitable giving strategies, Jonathon helps donors maximize available tax benefits (thereby reducing the “cost of giving”) by implementing IRS-sanctioned trust strategies such as charitable remainder trusts and charitable lead trusts. For every one dollar of tax savings, the donor and the donor’s family have one more dollar to give away to charity or their private family foundation.

Enhanced Charitable and Philanthropic Giving – “Optimized CLAT”

• The Optimized CLAT (OCLAT) is a special version of a charitable lead annuity trust that has been designed to optimize the tax and economic benefits to the contributor. An OCLAT is ideal for persons seeking to create a “giving engine” for tax-favored philanthropy during their lifetime. The OCLAT is the only tax planning vehicle in existence that generates a dollar-for-dollar tax deduction in the year of funding (providing immediate tax savings); returns an expected 1-5x of the initial contribution back to the contributor; immediately exempts the contributed assets from the 40% federal gift and estate tax, and exempts the transferred assets from the contributor’s personal creditors.

California “Prop 13” Real Property Tax Planning

• Jonathon’s clients benefit from his expertise with respect to the arcane California “Proposition 13” real property tax deferral rules. By properly structuring lifetime and testamentary gift transfers, owners of valuable California real estate can defer (and sometimes avoid) property tax reassessment that would otherwise occur at death. In addition to directly advising clients on these issues, Jonathon is engaged by both California and non-California licensed attorneys as expert co-counsel to assist clients with valuable California real property holdings.

Modification of Irrevocable Trusts

• Jonathon is often engaged to “clean up” situations in which an existing irrevocable trust contains unfavorable terms that are causing (or could cause) tax or non-tax problems. Depending on the situation, Jonathon may offer up to a half-dozen solutions to modify the trust terms and solve these problems.

Business Formation and Succession

• In the context of estate planning, Jonathon routinely assists clients in establishing family entities to centralize management of assets, maximize retained control, and assist with inter-generational transfers. In the context of active operating businesses, Jonathon is adept at handling matters involving concentrated positions, partnership and S corporation income tax issues, executive incentive compensation planning, and business succession planning.

International Estate Planning

• Clients with large estates oftentimes have international holdings or dual citizenship/residency, particularly in Canada, Asia and Mexico. In these situations, Jonathon works with a client’s advisors around the world to achieve a coordinated, tax-efficient, international estate plan.

Estate and Trust Administration

• Jonathon helps families prepare for and navigate the emotional and technical post-death estate administration process. His role includes advising executors (or, in Arizona, “personal representatives”) and trustees regarding fiduciary duties, notifying beneficiaries of their interests, reviewing estate documents, allocating and dividing assets, and advising on the income and estate tax consequences of death and potential ongoing trust administration. He also helps individuals and families identify and overcome challenges relating to concentrated asset positions (such as real property, farmland and family businesses), disputes with the IRS and state tax agencies, fiduciary conflicts of interest, and other issues common to estate administration.

Estate and Trust Litigation

• Jonathon helps families achieve harmony and develop amicable solutions in the event of disagreement. Unfortunately, some estate-related disputes are unavoidable. In this context, Jonathon works closely with Frazer Ryan’s trust and estate litigation attorneys to resolve the situation in a timely and cost-efficient manner. He often serves in an advisory role, interpreting technical terms of the estate documents and providing guidance with respect to income and estate tax consequences.

Personal

• Outside of the office, Jonathon treasures his time with his wife and two young children. They primarily live in Scottsdale, but their favorite time of the year is the summer, when the whole family sets sail to Paris to beat the Arizona heat in their Saint-Germain-des-Pres flat (and Jonathon takes advantage of the nine-hour time zone difference). Jonathon is also a performance car enthusiast and passionate collector of Ferraris, Porsches, and BMWs. On the weekend, you can usually spot him (and one of his kids riding shotgun) at Cars & Coffee or participating in high-performance driving events.

Certifications

• Certified Specialist in Estate Planning, Trust & Probate Law: State Bar of California

Birthplace

• Phoenix, Arizona

In the News

• How Pro Athletes Can Hit an Estate-Planning Home Run
• Frazer Ryan Goldberg & Arnold voted as a top law firm in 5 Ranking Arizona categories in the 2024 issue
• How a former IRS boss optimizes his charitable trust to support his alma mater – and give assets to his children tax-free
• Az Business Leaders 2024 recognizes three Frazer Ryan senior partners
• Selling your medical practice? Optimize the sale with this triple tax-advantaged strategy
• Az Business Leaders 2023 recognizes four Frazer Ryan senior partners
• Jonathon Morrison in Forbes magazine: OCLAT offers year-end tax deductions, wealth growth
• Optimized CLAT FAQs, Part 4: Remainder Assets, Tax Filings, Logistics, Fees
• Optimized CLAT FAQs, Part 3: The Charitable Lock-Up Period
• Optimized CLAT FAQs, Part 2: IRS Approval and the Upfront Tax Deduction
• Optimized CLAT FAQs, Part 1: The Basics
• Jonathon Morrison is selected as a Forbes contributor
• Optimized CLAT (OCLAT): “Opt out” of immediate income taxes by promising to make charitable gifts in the future