Sales to IDGTs
Can Be Both Powerful and Risky
The Law and the Math

(Unless You Do Them Right!)

For your high net worth and business owner clients, Sales to Grantor Trusts (also known as “IDGTs”) have always been a very attractive planning option. However, things may change quickly.

The 2024 elections and sunset of the TJCA at the end of 2025, nearly assures significant tax reform is coming. Moreover, if interest rates decrease in the meantime as is broadly expected, there may be a limited window of opportunity to act.

President Biden’s budgets and several tax bills circulated over the past few years propose to eliminate the benefit of sales to defective trusts. Specifically, the general idea is to treat these sales as taxable for income tax purposes after the new statute’s effective date. This would significantly increase the immediate tax cost of such planning and likely eliminate the IDGT strategy.

To help navigate the current environment, we have brought in nationally renowned CPA and tax planning expert, Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), for a very timely and practical presentation entitled, “How Sales to Grantor Trusts Can Benefit Your Clients in 2024”.

During this 108-minute program, Bob will address the following:

• How proposed changes impact traditional sales to grantor trusts
  • Make sales to non-grantor trusts as early in the life of the asset being sold to minimize gain
  • Using non-grantor trusts
  • Grandfathering rules

• Assuring Grantor Trust status

• Balancing bet-to-live and bet-to-die strategies

• Intentionally Defective Grantor Trust (IDGT) strategies including
  • Sales to IDGTs
  • Structuring IDGT sales to avoid Sections 2701, 2702 and 2036 (and the Woelbing case)
  • Sales to an IDGT with a SCIN hedge

• How to design note sales

• The truth about the “9-to-1” seed money ratio

• The use of guarantees

• Applying Rev. Rul. 93-12 when your client has more than one child

• Protective clauses for revaluation including the Wandry, Petter, McCord, and Christianson cases

• Understanding and avoiding the mistakes highlighted in Smaldino v. Commissioner, T.C. Memo 2021-127

• Designing QTIPs, GRATs, and LPA overflow clauses

• GRAT overflow clauses and the new CCA

• And much, much more!

Your purchase includes an instantly downloadable video and audio recording and PDF handout materials.  A PDF transcript is available as an add-on for an additional fee.