Trella·Trusts
Pre-liquidity QSBS planning

The QSBS trust built to survive the audit.

As the IRS turns its attention to trust stacking, the cheap-and-fast structures are the most exposed. TrellaTrusts is the opposite — independent trustees, real legal opinions, and a documented case for every trust.

01Confirm & attestVerify §1202 eligibility
02Design with counselAttorney-drafted trusts
03Fund independentlyNamed Nevada trustee
04Maintain the defenseA living paper trail
The shift

Stacking is no longer a place to cut corners.

In 2026, Treasury signaled it is taking a close look at QSBS trust stacking — scrutinizing structures that recycle exclusions without real economic separation, “friendly” trustee arrangements, and last-minute transfers. The exclusion is very much alive. What changed is that defensibility now matters more than speed or price.

$15M+
Federal exclusion at stake per properly-structured trust.
3 doctrines
Step-transaction, reciprocal-trust, economic-substance.
The line
Early, independent, documented — what we build around.
Why TrellaTrusts

Defensibility, engineered in — not bolted on.

Most providers optimize for cheap and fast. We optimize for the one thing that matters when the IRS asks questions: real substance, and the paper to prove it.

01

Independent trustees, by name

Choose from a panel of established, independent Nevada corporate trustees. No house-owned trustee, no conflict.

02

Real legal work — and an opinion

Trusts drafted and reviewed by attorneys of record, with a should-level tax opinion and genuine privilege behind it.

03

Substance by design

Non-reciprocal terms, early-transfer discipline, and a documented non-tax purpose for every trust — your defensibility file.

04

The whole lifecycle

Eligibility attestation, valuations, Form 709, annual returns, and §1045 planning — through your exit and beyond.

Who it's for

Built for founders who plan early.

  • Founders and early employees holding QSBS-eligible C-corp stock.
  • Real conviction and runway — ideally 18+ months before a likely exit.
  • Planning before a term sheet or LOI, while the best options are open.
  • People who'd rather be defensible than merely cheap.
“The best time to structure was before the round. The second-best time is now — before the deal is in sight.”
The timing principle
Founding cohort

Join the waitlist.

We're onboarding a limited first cohort of founders. Tell us about your situation and we'll be in touch with early-access terms.

No spam. Your details are never shared. TrellaTrusts is not a law firm and this is not legal or tax advice.

You're on the list.

Thank you. We'll reach out shortly with founding-cohort details and next steps.

Questions

What founders ask.

Is QSBS stacking still legal?+

Yes. The §1202 exclusion — and multiplying it across separate non-grantor trusts — remains available under current law. Treasury is examining aggressive structures; well-documented, independent, early planning is precisely what stays defensible.

What makes TrellaTrusts different?+

Genuinely independent, named trustees; real legal representation with a written should-level tax opinion; and a documented economic-substance file for every trust. Defensibility is the product, not the fine print.

When should I set this up?+

As early as possible — ideally well before a term sheet, while your share price is low. Waiting until a deal is in sight is the single biggest risk.

Are you a law firm?+

No. TrellaTrusts is not a law firm and does not provide legal or tax advice. Your trusts are drafted and reviewed by independent attorneys, and you receive your own counsel of record.

What does it cost?+

Flat, transparent pricing that includes the independent trustee, legal opinion, qualified valuation, and ongoing reporting. Founding-cohort members receive early-access terms — join the waitlist for details.