High-income business owners often face a familiar problem. They earn well, but a large portion goes to taxes. Traditional planning tools offer some relief, but they come with limits, strict rules, and capped contributions. Over time, these limits reduce their effectiveness.
Ken Crabb, founder of the Restricted Property Trust, has built a structure that addresses this issue directly. His approach focuses on tax efficiency, long-term growth, and business continuity. It does so within the boundaries of existing tax law.
The Restricted Property Trust (RPT) is designed for business owners who want more control over how their income is taxed and preserved, while working differently from common retirement plans.
The Problem with Conventional Tax Planning
Most business owners rely on qualified plans like 401(k)s or profit-sharing structures. These plans are useful, but they come with restrictions, such as contribution limits being strict, participation rules, and difficult testing requirements, which often make it harder for owners to maximize benefits.
High earners cannot fully protect their income through these tools alone.
Another issue is timing. Many plans defer benefits far into the future. That means limited flexibility in how and when funds are accessed.
There is also the question of tax treatment. In many cases, contributions and withdrawals are taxed in ways that reduce overall efficiency. Business owners end up paying more than expected over time.
These limitations create a need for alternative strategies that remain compliant but offer greater flexibility.
How the Restricted Property Trust Changes This
The Restricted Property Trust is not a qualified plan.
Because it operates outside traditional plan rules, it avoids common limits. There are no standard contribution caps and no requirement to include all employees. Business owners can design participation based on their needs.
The structure works through employer-sponsored contributions. These contributions are fully tax-deductible to the business. At the same time, only a portion is taxable to the participant.
The remaining funds a life insurance policy within the trust. This policy grows on a tax-deferred basis. Over time, it builds cash value while also providing a death benefit.
A critical feature is the “substantial risk of forfeiture.” If the employer fails to meet contribution obligations, the policy is forfeited to a designated charity. This condition ensures the plan meets IRS requirements and avoids being classified as deferred compensation.
This is how the RPT stays compliant while offering advantages not available in traditional structures.
IRS Compliance and the Six-Year Investigation Outcome
Tax strategies often raise questions about compliance. The Restricted Property Trust faced this directly.
Ken Crabb underwent a six-year IRS investigation that began in 2018. The investigation focused on whether the structure violated tax rules under IRC Section 6700.
After an extensive review, the IRS ended the investigation in February 2024 without penalties or charges.
Crabb described the experience as: “It was a brutal six years, but it’s great to have that investigation in the rearview mirror so we can now focus 100% on delivering the Restricted Property Trust to successful taxpayers all over America.”
This outcome shows that the structure was tested under scrutiny and remained intact. The absence of penalties signals that the framework operates within legal boundaries.
Services and Value Offered by the Restricted Property Trust
The Restricted Property Trust provides a focused set of benefits for business owners and executives:
- Fully tax-deductible employer contributions.
- Partial taxation for participants, reducing the immediate tax burden.
- Tax-deferred growth within a life insurance policy.
- No contribution limits tied to qualified plan rules.
- No impact on existing retirement plans.
- Asset protection from creditors.
- Flexible exit options, including income streams or policy retention.
- Built-in death benefit for business continuity.
These features work together to create a structured, long-term approach to wealth management.
The plan is especially suited for high-profit partnerships, medical and financial firms, executives earning significant annual income, and corporations seeking tax-efficient compensation strategies.
Each participant can choose their contribution level. This adds flexibility that is often missing in traditional plans.
Conclusion
Traditional tools limit how much high-income earners can protect and grow. The Restricted Property Trust removes many of these limits while staying within IRS rules. Ken Crabb’s approach focuses on structure, compliance, and long-term value. The six-year IRS investigation and its outcome have added an extra layer of credibility to the model.
All in all, the Restricted Property Trust offers a practical and legally sound option for business owners looking to reduce tax exposure and build lasting financial security.
