What the $7,000 Annual Fee for a Cook Islands Trust Pays For
Blake Harris Law's Cook Islands Trust annual fee is a flat $7,000. Here is where each dollar goes, what it includes, what it does not, and how it compares.
Most of the cost of a Cook Islands Trust is paid once, at setup. The structure also has an ongoing cost, and it is reasonable to want to know exactly what that money buys. This page explains how the firm's flat $7,000 annual fee is divided, what each party does for its share, what the fee does not cover, and how it compares with what we generally see elsewhere.
Where Does the $7,000 Go?
Into three parts, each paid to the party doing the work. The same breakdown appears on our pricing page.
$5,000 to the trust company. The licensed Cook Islands trustee holds legal title to the trust assets and runs the trust. Its share covers all trustee services: administration, amendments, adding or removing beneficiaries and successors, processing distributions, and the regulatory and operational work of keeping the trust in good standing. When Atlas is the trustee, none of that is billed by the hour. It also covers the annual Cook Islands government fees for both the trust and its Cook Islands LLC, so the client does not receive a separate government invoice for either entity.
$1,500 to Blake Harris Law. This gives clients unlimited access to the firm's attorneys and paralegals for the life of the structure: questions, reviews, and counsel as circumstances change. The firm does not bill by the hour, so a client never has to weigh whether a call is worth making.
$500 to the Protector. Independent oversight of the trustee, including the power to remove and replace it, which we explain in the roles of trustee, Protector and settlor.
How that compares with the wider market is set out below.
Who Is the Trust Company?
For new engagements the firm generally recommends Atlas Trust Company, a licensed Cook Islands trustee co-founded by Blake Harris. We disclose that relationship because it is relevant to the fee: the $5,000 trust-company share goes to Atlas when Atlas is the trustee. Atlas does not charge hourly fees, so that share covers all of its trustee services for the year.
Clients are free to choose another licensed Cook Islands trustee. Our guide to choosing a Cook Islands trustee sets out what to look for, including fee transparency.
What Is Not Included?
The annual fee covers keeping the structure running. Unlimited access covers consultations and ongoing counsel. Work that depends on the client's own circumstances, or on events no one can schedule, is handled separately.
U.S. tax reporting. For U.S. tax purposes, a Cook Islands Trust is generally a foreign grantor trust. Its income is reported on the settlor's own return, as explained in tax treatment of a Cook Islands Trust. The structure also carries annual information filings, including Form 3520, Form 3520-A, FinCEN Form 114 (the FBAR) and, for many clients, Form 8938. These filings are generally prepared by the client's CPA, and their preparation is not part of the annual fee. Because Form 3520-A is filed on behalf of the trust itself, the CPA will typically need information from the trustee to complete it.
Penalties for missed or late filings are significant, so we recommend a CPA with foreign-trust experience. The filings are set out in Cook Islands Trust reporting: FBAR, Form 3520, Form 8938. For why the paper trail strengthens the plan rather than weakening it, see why offshore trust reporting works in your favor and foreign trust reporting: what you actually need to know. For the audit question, see will an offshore trust get you audited?
Defending the trust. If a creditor challenges the trust, defending it requires additional work from U.S. counsel and potentially Cook Islands counsel, that work is billed separately by the law firms assisting with the defense. The cost depends on the claim, the court and how far the creditor pursues it. What happens if a U.S. court orders you to repatriate trust assets explains how that kind of challenge typically unfolds.
Banking and investment costs. Bank account maintenance is passed through at cost. Investment management or advisory fees are set by the bank or adviser the trust uses and are paid separately.
Funding and restructuring. Moving new assets into the structure can carry third-party costs. For real estate, that can include deeds, recording fees and title work. Our Cook Islands Trust cost breakdown covers setup and these event-driven costs in more detail.
How Does It Compare?
Across the market, annual administration for a Cook Islands Trust typically runs from about $7,000 to $10,000, as our cost breakdown sets out. A flat $7,000 sits at the lower end of that range. A flat fee also has a practical advantage. Fee structures vary, and where administration is billed by the hour or routine work such as distributions is charged separately, the annual cost can be hard to predict. A single published figure lets a client budget for the structure before committing to it.
Is It Worth It?
For someone moving $2 million into the structure, $7,000 a year is about 0.35% of the protected assets. That is a small trade off on a structure that could potentially make the difference between keeping that wealth or leaving it at risk.
Frequently asked
Frequently asked questions
A flat $7,000 a year. $5,000 goes to the trust company, $1,500 to Blake Harris Law and $500 to the Protector, with no markup added by the firm.
No. The annual information filings, including Form 3520, Form 3520-A, FinCEN Form 114 (the FBAR) and, for many clients, Form 8938, are generally prepared by the client's CPA, and their preparation is not part of the annual fee.
No. If a creditor challenges the trust, defending it requires additional work from U.S. counsel and potentially Cook Islands counsel, which is billed separately by the law firms assisting with the defense.