602.277.2010
602.277.2010
Jonathon Morrison
Jonathon Morrison

Senior Partner

    Overview

    A renowned innovator and technician in his space, Jonathon’s thought leadership and knack for developing novel, cutting-edge solutions has resulted in multiple advances in the field of advanced tax and estate planning. In addition to publishing multiple peer-reviewed articles featured on the cover of the national Estate Planning Journal (the top legal journal in the field), Jonathon has been featured in Forbes, Fortune, Bloomberg, and Barrons, as well as several nationally syndicated podcasts, with respect to strategies involving income and estate tax minimization, charitable and philanthropic giving, business exit and succession planning, and asset protection.

    For nearly 20 years, Jonathon has practiced with the top tax and estate planning law firms in Silicon Valley and Phoenix. Before his family relocated to his hometown of Phoenix in 2015, Jonathon worked with the personal tax planning group associated with Wilson Sonsini, the “go-to” law firm in Silicon Valley which led IPOs for Apple, Google, Amazon, Tesla, and hundreds of other top tech companies. During this time, Jonathon designed and implemented estate plans for hundreds of the wealthiest individuals in the world, including founders, C-level executives, venture capitalists, and angel investors. As soon as he arrived in Phoenix, Jonathon’s unique skill set quickly distinguished him as one of Arizona’s premier tax and estate planners.

    A pioneer at the forefront of the tax and estate planning sector, Jonathon is also credited as the developer and publisher of multiple innovations in the field, including (i) the ‘optimized gift trust’ (OGT) (a solution for wealthy individuals to reduce the federal estate tax, but retain maximum access and control of the assets within IRS limits), (ii) the ‘optimized CLAT’ (OCLAT) (a special variant of charitable lead trust which maximizes the tax and economic benefits of philanthropy, as well as donor control), and (iii) the ‘marital multiplier trust’ (MMT) (a variant of non-grantor inter vivos QTIP trust designed to maximize the benefits of QSBS stock).

    Jonathon estimates that he has been directly involved in more than 500 major advanced estate planning transactions that include one or more of the following vehicles:

    • Optimized Gift Trusts (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)
    • QSBS Marital Multiplier Trusts (MMTs) and Inter Vivos QTIP Trusts,
    • Nevada Incomplete Non-Grantor Trusts (NING Trusts)
    • Asset Protection Trusts (APTs), both 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

    Practice Areas

    • Tax Planning
    • Estate Planning, Wills and Trusts
    • Business Formation
    • Probate and Trust Administration
    • M&A Transactions
    • State and Local Tax Law
    • Property Tax Law
    • California Probate, Real Estate and Taxation

    Honors & Awards

    • The Best Lawyers in America® (Closely Held Companies and Family Businesses Law), 2022-present
    • Az Business Leaders (Tax Law), AZ Big Media, 2023, 2024
    • Certified Specialist in Estate Planning, Trust & Probate Law: State Bar of California

    Bar & Court Admissions

    • Arizona, 2015
    • California, 2007

    Education

    • J.D., Taxation, University of California Hastings College of Law, 2007
    • B.S., cum laude, University of Arizona Eller College of Management (Accounting & Finance), 2004

    Professional Memberships

    • State Bar of Arizona: Probate and Trust Law Section; Tax Law Section
    • State Bar of California
    • Central Arizona Estate Planning Council
    • Valley Estate Planners
    • Planned Giving Roundtable of Arizona

    Articles & Presentations

    Published Articles

    Select Presentations

    • “Pre-2026 Sunset Planning Using Optimized Gift Trusts & Funding Designs,” East Valley Estate Planning Counsel, September 2024
    • “The Optimized Gift Trust & Funding Designs: A Turnkey Solution for Pre-2026 Gifts,” Phoenix Children’s Foundation, Professional Advisor Summit, September 2024
    • “Advanced Charitable Trust Planning Strategies,” Arizona Community Foundation, Professional Advisors Series, September 2022
    • “Planning Strategies in Advance of Potential Tax Reform,” East Valley Estate Planning Council, September 2021
    • “Charitable Planning Using CLATs,” CalCPA Phoenix Tax Workshop, July 2021
    • “Pre- and Post-Sale Planning for You, Your Company and Your Family,” Northern Trust Conference for Business Owners, February 2020
    • “Estate Planning and Charitable Trust Strategies,” Desert Botanical Garden Donors Circle, Summer 2019
    • “Charitable Tax Strategies,” JP Morgan Wealth Advisors, Summer 2019
    • “California Conundrums: What Arizona Attorneys and Advisors Must Know When Planning for Clients with California Ties,” Valley Estate Planners, January 2019
    • “Using Charitable Lead Annuity Trusts To Maximize the Economic Benefits of Charitable Giving”, Arizona Society of Certified Public Accountants (ASCPA) Annual Conference, June 2018
    • “Introduction to Tax-Efficient and Maximum Impact Charitable Giving,” Valley of the Sun United Way, February 2018
    • “California Conundrums: What Arizona Attorneys and Advisors Must Know When Planning for Clients with California Ties,” Scottsdale Estate Planners, January 2018
    • “Creative Charitable Lead Trust Strategies,” Valley Estate Planners, November 2017
    • “7 Uses of Charitable Trusts to Achieve a Donor’s Economic Goals,” Southwest Autism Research & Resource Center (SARRC), October 2017
    • “Creative Charitable Trust Strategies,” A New Leaf, May 2017
    • “Creative Charitable Trust Strategies,” Planned Giving Roundtable Annual Conference, May 2017
    • “Creative Charitable Strategies,” Maricopa County Bar Association, February 2017
    • “Zeroed Out Grantor CLAT: The High-Earner’s Charitable Super-IRA,” October 2016
    • “How to Use Grantor Charitable Lead Annuity Trusts,” Phoenix Rescue Mission, September 2016
    • “Advising Your Clients About Charitable Remainder Trusts,” Edward Jones Financial Advisors, June 2016
    • “Pre- and Post-Sale Planning for You, Your Company and Your Family,” Merrill Lynch Conference for Business Owners: M&A Solutions for Privately Held Companies, April 2016
    • “Interstate Tax Issues,” State Bar of Arizona, Probate & Trust Section, March 2016
    • “Charitable Giving Strategies,” Dignity Health, February 2015

    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

    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.

    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.

    Birthplace

    • Phoenix, Arizona

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