How to Invest $10 Million

What changes at $10 million

The jump from $2M–$5M to $10M isn't just a bigger version of the same problem. Three structural things shift:

1. You're a qualified purchaser (QP). Under Section 2(a)(51) of the Investment Company Act of 1940, you become a "qualified purchaser" once you own $5 million or more in investments — a higher bar than the accredited investor standard ($1M net worth).¹ QP status unlocks access to Section 3(c)(7) funds, which include institutional private equity, private credit funds, hedge funds, and venture strategies with no 100-investor limit. The universe of alternatives available to you roughly triples compared to what's accessible as merely an accredited investor.

2. Estate planning becomes structurally urgent. At $5M, estate planning is about beneficiary designations and avoiding probate. At $10M, a married couple's combined estate approaches $20M+. With the OBBBA estate exemption permanently set at $15M per person ($30M combined),² you're still below the federal threshold as a couple — but you're not far from it. State estate taxes (several states have exemptions as low as $1M), future appreciation, and life insurance death benefits can push an estate past the threshold. GRATs, SLATs, and dynasty trust planning all make more economic sense at $10M than at $3M.

3. Tax drag is a larger absolute number. At $3M, 1% tax drag costs $30,000/year. At $10M the same 1% drag costs $100,000/year — more than many households earn. Every percentage point of efficiency — asset location, tax-loss harvesting, deferral structures — generates real money in absolute terms.

Asset allocation at $10 million

At $10M the standard three-bucket framework still applies, but the weights and instruments shift:

The meaningful difference at $10M: the alternatives bucket becomes genuinely institutional. Below QP status, you're limited to interval funds, BDCs, and closed-end funds that provide PE/credit exposure but with embedded fee layers. At QP status, you can invest directly in institutional LP interests at lower carry structures (10–15% vs the retail 20%+) and with access to co-investment deals alongside the fund — potentially fee-free on the co-invest portion.

Qualified purchaser alternatives: what opens up

The practical difference between accredited investor and QP access isn't just legal — it's economic. Section 3(c)(7) funds are structured for institutional investors and typically offer better terms:

Direct indexing at scale

With $10M in taxable assets (or a large taxable component), you can run multiple direct index sleeves simultaneously — for example, a US large-cap sleeve, a US small-cap sleeve, and an international sleeve — each with independent tax-loss harvesting. This setup generates more harvesting opportunities than a single sleeve, while also allowing factor tilts (value, quality, momentum) at the individual-stock level without sacrificing diversification.

Providers like Parametric, Aperio (BlackRock), and Vanguard Personalized Indexing can run multi-sleeve direct index portfolios starting around $500K–$1M per sleeve. At $10M total, a $3M–$5M taxable account would support two or three sleeves with meaningful harvesting volume. The fee (0.15%–0.35% per sleeve) is typically recovered within 1–3 years through systematic harvesting at the 23.8% LTCG+NIIT combined rate.⁴

Estate planning priorities at $10 million

Even with the OBBBA's $15M-per-person federal exemption, a $10M household has planning reasons to act now:

State estate taxes. Fifteen states plus DC impose state-level estate taxes, many with exemptions of $1M–$5M. A couple with $10M combined assets living in Massachusetts, Oregon, Washington, or Minnesota faces potential state estate tax on assets above the state threshold — regardless of the $30M federal exclusion. The planning tools are the same (trusts, lifetime gifting), but the urgency is higher in high-estate-tax states.

Future appreciation. A $10M estate that grows at 7% nominally for 10 years reaches $19.7M. A couple's combined estate can reach $30M in a decade without any new savings. Life insurance death benefits are included in the taxable estate unless held inside an Irrevocable Life Insurance Trust (ILIT). If you hold a $3M life insurance policy outside an ILIT, that $3M is inside your estate.

GRATs and SLATs become economically meaningful. At $10M, a $3M GRAT growing at 9% against a §7520 hurdle rate of 5.00% (May 2026)⁵ transfers approximately $465,000 to heirs tax-free — without using a dollar of your $15M exemption. The economics of trust strategies improve materially as the base gets larger. See our GRAT, SLAT & QPRT trust guide for the full mechanics and calculator.

Portability election. When the first spouse dies, a portability election preserves the deceased spouse's unused exemption for the survivor. This is mechanical but consequential — it requires filing an estate tax return within 5 years of death even if no tax is owed, and the election is easily missed. Make sure your estate plan documents include a standing instruction to file. See our estate planning guide for $2M–$20M families.

Tax strategies that pay more at $10 million

Roth conversion runway

At $10M with a $2M–$4M traditional IRA component, the RMD math is particularly punishing. A $3M traditional IRA at age 73 generates a first-year RMD of roughly $112,000 (using the Uniform Lifetime Table factor of 26.5) on top of any other income — pushing you deep into the 35–37% bracket and likely triggering IRMAA surcharges of $3,000–$10,000/year or more per person. The Roth conversion window between early retirement (62) and RMD age (73 or 75) is worth modeling carefully at this portfolio size. See our Roth conversion strategy guide + calculator and IRMAA planning guide for the detailed scenarios.

Charitable strategies

At $10M, charitable giving can be a genuine wealth-transfer tool, not just philanthropy. Donating $1M in appreciated stock with a $100K basis to a DAF eliminates $214,000 in capital gains tax (at 23.8% combined LTCG+NIIT rate) while generating a charitable deduction against ordinary income at 37%.⁴ A Charitable Remainder Trust (CRT) on the same position provides income for life plus a charitable deduction, while removing the asset from your taxable estate. These strategies scale non-linearly with portfolio size. See our charitable giving strategies guide for the DAF vs. CRT comparison.

Business owner tax shelters

If any portion of your $10M came from or is supported by a business, the combination of solo 401(k) + cash balance plan at $10M+ income levels can shelter $200,000–$300,000/year in pre-tax contributions — producing $74,000–$111,000 in annual federal tax savings at 37%. This compresses the remaining taxable income, shifts the Roth conversion math, and builds sheltered assets for future step-up or conversion planning. See our cash balance plan guide.

What to pay for advice at $10 million

At this wealth level, the advisor fee structure matters more than at $2M — the absolute cost is higher, and the opportunity cost of a misaligned structure is real.

The 20-year cost difference between 1% AUM and a $20,000/year flat retainer on $10M, at 7% gross return, is approximately $4.7 million in foregone wealth — that's the compound cost of 0.8% annual drag on a $10M starting base. See our fee-only vs. 1% AUM full comparison for the exact math at multiple portfolio levels.

Five mistakes $10 million investors make

1. Staying at a wirehouse because "they know the account." Relationship inertia at this wealth level is expensive. A 1% AUM fee on $10M is $100,000/year that could be redirected to Roth conversions, direct indexing fees that actually pay off, or alternatives access. Institutional custodians (Fidelity Institutional, Schwab Advisor Services, TD Ameritrade) hold accounts of any size; the advisor and the custodian are separate decisions.
2. Treating the estate plan as done because you're "under the $15M exemption." State estate taxes, future appreciation, ILIT planning for life insurance, and portability elections are all active considerations well below $15M. An "under the exemption" rationalization keeps people from doing trust planning that would transfer hundreds of thousands of dollars of future appreciation out of their estate tax-free.
3. Ignoring qualified purchaser access. Many investors with $5M–$10M in investable assets still access alternatives through BDCs and interval funds — the retail tier — because no one has walked them through QP eligibility. The fee and return difference between retail and institutional alternative access is substantial over a decade. A $1.5M PE allocation at institutional terms vs. a fund-of-funds structure could represent $200,000–$500,000 in net-of-fee value over the fund's life.
4. Letting cash drag continue past 6 months. At $10M, $500,000 parked in checking earns roughly 0% while T-bills yield ~4.5–5%.⁶ That's $22,500/year in visible foregone income, compounding. Sweep accounts into a money market or T-bill ladder the day new cash arrives.
5. Underutilizing the Roth conversion window. The years between retirement (when earned income drops) and RMD age (73 or 75) are the only window where you can convert traditional IRA assets at predictable rates before RMDs force distributions at whatever marginal rate the IRS schedules. At $10M with a $3M+ traditional IRA, this window is one of the highest-leverage financial decisions in the entire retirement horizon.

Get matched with a fee-only advisor who works with $10M+ portfolios

The decisions at this wealth level — QP alternatives access, GRAT timing, Roth conversion sequencing, state estate tax planning, direct indexing at scale — are where a fiduciary fee-only advisor earns back their cost many times over. We match you with advisors who specialize in this wealth range and charge flat retainers, not 1% AUM.

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Sources

1. Investment Company Act of 1940, § 2(a)(51) — Qualified Purchaser definition. An individual who owns not less than $5,000,000 in investments, or a company that owns not less than $25,000,000 in investments. Threshold has not been adjusted for inflation since 1996; SEC separately updated "qualified client" thresholds effective June 29, 2026 (different standard, Rule 205-3).
2. IRS: Estate and Gift Taxes — OBBBA permanent exemption. Federal estate and gift tax exemption permanently set at $15M per individual under the One Big Beautiful Bill Act (OBBBA, enacted July 2025), indexed for inflation from 2026. Combined for married couples via portability election: $30M. The TCJA 2025 sunset was eliminated.
3. Commons Capital: What Is a Multi-Family Office? Multi-family offices typically require $25M–$50M in investable assets, with some firms starting at $30M. Below that threshold, a boutique fee-only RIA with integrated tax and estate services typically delivers comparable planning at lower cost.
4. IRS Rev. Proc. 2025-32 — 2026 Capital Gains and NIIT thresholds. 2026 MFJ: LTCG 15% on taxable income $96,700–$613,700; 20% above $613,700. Net Investment Income Tax (NIIT) 3.8% on investment income above $250,000 MAGI (MFJ) — not inflation-indexed per IRC § 1411. Combined top rate: 23.8%.
5. IRS Internal Revenue Bulletin 2026-19 — § 7520 Rate for May 2026. Applicable Federal Rate (§ 7520) for May 2026 is 5.00%. Used to calculate GRAT hurdle rate, annuity values, and installment-sale imputed interest.
6. TreasuryDirect: T-Bill Auction Results. Current 3-month and 6-month T-bill rates. Rates change weekly; verify current yield at TreasuryDirect before making cash-management decisions.

Return assumptions used in the calculator (5% / 7% / 8.5% nominal) are illustrative long-term estimates based on broad historical equity and bond market returns. They are not guarantees and may differ materially from actual outcomes. Capital gains tax rates verified against IRS Rev. Proc. 2025-32 for tax year 2026. OBBBA estate exemption: enacted July 2025. QP threshold: Investment Company Act §2(a)(51). MFO minimums: industry survey data; individual firms vary. Content verified May 2026. Consult a qualified financial advisor and CPA for your specific situation.