What an Estate Plan Might Look Like for Larry Ellison vs. Elon Musk—And What You Can Borrow From It

Bloomberg reports Larry Ellison has just topped Elon Musk as the world’s richest man. Here’s how UHNW founders like Ellison and Musk might structure estate plans—and what you can adapt.

The headline news (and why it matters for planning)

On September 10, 2025, Bloomberg reported that Larry Ellison became the world’s richest person, ending Elon Musk’s nearly year-long run at No. 1, after Oracle’s earnings-driven surge lifted Ellison’s fortune by roughly $101 billion in a day. Bloomberg.com

This kind of extreme, concentrated public-stock wealth (Ellison’s stake in Oracle is ~41%) has very specific estate-planning implications—especially compared with a founder like Elon Musk, whose net worth spans a mix of public and private companies (Tesla, SpaceX, xAI, X). Bloomberg.comForbesBankrate

Below, we sketch what comprehensive estate plans for each might emphasize—and then translate the lessons for families who aren’t billionaires but still face estate-tax exposure.

Estate planning priorities for Larry Ellison

Profile highlights that drive the plan:

• Primary asset: ~41% of Oracle (public, volatile, insider constraints). Bloomberg.com

• Residency & state tax: Much of Ellison’s life is in Hawai‘i (he owns ~98% of Lānaʻi) where a state estate tax applies above $5.49M, at 10–20%. That’s on top of federal estate tax. WikipediaSmartAsset

• Philanthropy: Longstanding focus on aging and biomedical research via the Ellison Medical Foundation. Ellison Medical FoundationWikipedia

Likely tools & structures:

1. Dynasty trusts in trust-friendly jurisdictions (e.g., South Dakota/Nevada) to hold Oracle shares and other assets long-term, balance asset protection, and use directed trustee models so professional committees manage investments/votes while family stewards mission.

2. Voting vs. non-voting recapitalizations (where feasible) to retain corporate control in a smaller, taxable slice while migrating economic value to trusts over time.

3. Rolling GRATs funded with appreciating Oracle stock to “skim” future appreciation to heirs at low transfer-tax cost (if returns beat the §7520 rate). GRATs are a classic fit for concentrated, high-beta stock. 

4. Charitable lead annuity trusts (CLATs) to front-load philanthropy (aligned with Ellison’s medical-research focus) while transferring remainder interests to family efficiently.

5. Liquidity planning to cover combined federal + Hawai‘i estate taxes (credit lines, staged sales under Rule 10b5-1 plans, or privately-placed life insurance owned by an ILIT). The updated SEC rules on 10b5-1 require cooling-off periods and added disclosures—important for insiders who gift or sell.

6. Real-estate entities/QPRTs for unique properties (e.g., Lānaʻi holdings, other trophy real estate) to manage valuation discounts, governance, and inter-generational stewardship.

Estate planning priorities for Elon Musk

Profile highlights that drive the plan:

• Assets across public/private companies: sizable position in Tesla (~12–13% range reported), plus large private stakes in SpaceX, xAI, and interests connected to X—each with different liquidity/valuation dynamics.

• Residency: Texas, which has no state estate or inheritance tax (estate planning can focus primarily on federal rules, plus domicile-maintenance formalities). 

• Philanthropy: The Musk Foundation focuses on education, pediatrics, renewable energy, space, and AI safety. 

Likely tools & structures:

1. Pre-liquidity planning for private company equity (SpaceX/xAI): early valuation freezes, defective grantor trusts, GRATs, and staged gifting to capture upside outside the taxable estate. 

2. Charitable remainder unitrusts (CRUTs) or DAFs funded with appreciated assets to diversify with tax deferral while meeting ongoing philanthropic goals through the Musk Foundation/DAF grants.

3. Rule 10b5-1 trading and gifting programs for Tesla shares to systematize gifts/sales while respecting insider-trading controls and cooling-off periods.

4. Governance trusts (voting/non-voting “split”) for control-sensitive holdings, with trust protector and succession mechanics to handle future board/leadership transitions.

5. Family mission statement embedded in trust instruments to align innovation-centric philanthropy with next-gen education and guardrails.

Federal estate-tax landscape (why timing matters)

• For 2025, the federal estate/gift exemption around $13.61M per person (double for married couples), with a top estate tax rate of 40%—and long-standing IRS guidance confirming no “clawback” for gifts made under the higher exemption. 

• States differ: Hawai‘i imposes an additional estate tax (exemption ~$5.49M; 10–20%), while Texas imposes none—a stark difference UHNW families weigh alongside lifestyle and business needs.

Practical translation: Ellison’s Hawai‘i exposure makes liquidity + GRAT/charitable lead trust + state-tax modeling especially urgent. Musk’s Texas domicile reduces state-tax friction, but federal exposure on concentrated stock and private-company upside still demands early, disciplined transfers.

The “core four” every high-net-worth family still needs

You don’t need a $300B fortune to borrow from billionaire playbooks. At a minimum, most clients should have:

1. Revocable living trust + pour-over will (avoid probate; keep continuity).

2. Financial + healthcare powers of attorney (incapacity planning).

3. Beneficiary audits for retirement accounts, life insurance, and TOD/POD assets.

4. Asset-segregation entities (LLCs/FLPs) for operating businesses or rentals.

From there, add: ILITs (to keep life insurance outside the estate), GRATs/CLATs for appreciating assets, and jurisdictional planning (situs/choice-of-law trusts) when appropriate.

Takeaways for founders & concentrated-stock executives

• Don’t let the market set your plan’s timing. Use rolling GRATs and pre-set 10b5-1 programs to methodically shift appreciation and fund liquidity. 

• Model your state layer. A Hawai‘i domicile vs. Texas domicile can change the marginal death-tax cost by double digits. 

• Bake control into the instrument. Directed trusts, trustee committees, trust protectors, and voting/non-voting splits maintain mission + control while moving economics to heirs or charity.

• Institutionalize philanthropy. Private foundations/DAFs and charitable lead trusts can advance impact goals and improve transfer-tax efficiency, as Ellison’s and Musk’s foundations illustrate. 

How Katie Charleston Law can help

Our estate, business, and IP teams regularly design founder-grade plans that coordinate corporate control, family governance, and tax efficiency—without losing sight of your mission. Whether you’re managing significant private equity, a concentrated public position, or a fast-growing operating company, we’ll right-size billionaire playbooks for your facts, jurisdictions, and goals.

Considering GRATs, dynasty trusts, or a liquidity plan around insider constraints? Let’s map your options and timeline.

This article is for general information only and isn’t legal or tax advice. Facts and laws change; your plan should be tailored to your assets, family, and jurisdictions.