A couple are almost at retirement age and have a net worth of $80,000,000. This couple has been married for over 30 years and is not interested in charitable giving. They have wills that leave eveything to the surving spouse and when the surviving spouse dies their estate will be given to each of their 3 children per stripes. They will not use any of their lifetime gift exemption.

When working on their estate planning they wondered if they will have to set up ABC trusts. Should they use these types of trusts for their estate? Part of them? Or none at all?