Contract analysis

1. Introduction and Purpose We write with reference to the Engagement Letter dated February 15, 2023 (the "Engagement Letter"), pursuant to which you retained Calderwood & Harkness LLP ("C&H" or the "Firm") to provide comprehensive generational estate planning services on your behalf. We are pleased to inform you that the engagement has been completed in accordance with its terms, and the matter is being closed effec

2. Overview of the Estate Plan 2.1 Estate Context As documented in the Preliminary Asset Inventory and Summary completed on March 1, 2023, and as refined through further analysis and valuation work conducted throughout the engagement, your gross estate at the commencement of planning was approximately $300,000,000. The composition of your estate is summarized as follows: With respect to the real estate holdings, the

3. Summary of Structures Implemented 3.1 Grantor Retained Annuity Trusts (GRATs) The cornerstone of the estate plan's wealth transfer strategy is a series of three GRATs, each structured as a "zeroed-out" GRAT in which the present value of the retained annuity interest equals (or nearly equals) the fair market value of the property transferred to the trust, resulting in a taxable gift of zero for federal gift tax pur

4. Complete Document Index Set forth below is a comprehensive index of all documents generated, executed, or obtained in connection with this engagement. The documents are organized by category and numbered sequentially for ease of reference. Each document is included in the closing document set delivered to you concurrently with this letter. 4.1 Engagement and Administrative Documents (Documents 1–7) 4.2 Memoranda a

5. Ongoing Obligations and Action Items The estate plan that has been implemented involves a number of ongoing obligations and administrative requirements. While Calderwood & Harkness's engagement has concluded as of the date of this letter, it is essential that you and your advisory team remain attentive to the following action items and compliance deadlines. We have prepared an Ongoing Obligations Summary Calendar,

1. Premium Contribution: You contribute the annual premium amount ($187,500) to Northgate Trust Company of Delaware as trustee of the ILIT. This contribution should be made sufficiently in advance of the premium due date to allow Northgate to process the payment to Beacon Life Assurance Company.

2. Crummey Withdrawal Notices: Within a reasonable time following each contribution (typically 30 days or less), Northgate must send written Crummey withdrawal notices to each of the three beneficiaries (Thomas, Katherine, and Olivia), informing them of their right to withdraw up to $5,000 of the contribution during a specified withdrawal period (generally 30 days from the date of the notice). A template Crummey With

3. Annual Exclusion and Exemption Usage: The annual contribution of $187,500 is treated for gift tax purposes as follows: • Annual exclusion coverage (based on Crummey withdrawal rights): $51,000 (3 beneficiaries × $17,000 annual exclusion for 2023). • Balance of premium treated as a taxable gift: $136,500 per year. • This annual taxable gift amount will be charged against your remaining lifetime gift tax exemption (

4. Exemption Sunset Monitoring: The currently elevated lifetime gift tax exemption of $12,920,000 (2023) is scheduled to sunset after December 31, 2025, reverting to approximately $5,000,000 (adjusted for inflation). If the sunset occurs, the annual premium contributions of $136,500 will consume remaining exemption at an accelerated pace relative to what would be available under a reduced exemption. We recommend moni

6. Recommendations for Future Review An estate plan of this complexity and magnitude should not be viewed as a static document or a one-time exercise. Rather, it should be treated as a living framework that is periodically reviewed and updated to reflect changes in law, family circumstances, and asset composition. We offer the following recommendations for future review. 6.1 Annual Review We recommend that you conduc

7. Engagement Conclusion We hereby confirm that all work contemplated under the Engagement Letter dated February 15, 2023, as supplemented by the Engagement Scope Addendum — Tax Advisory Services (Document 6), has been completed in full. The original engagement fee estimate was $1,850,000, with an agreed-upon fee cap of $2,100,000. A final billing summary reflecting all fees and disbursements incurred in connection w