Sales to IDGTs
Can Be Both Powerful and Risky
(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.
Sections the tax bill would turn grantor trust taxation on its head, and would adversely impact note sales to grantor trusts. Rising interest rates, a volatile market, and proposed tax reforms only complicates the planning.
More specifically, Section 1062 of the tax bill provides that the grantor trust rules are ignored whenever there is a transfer of property between a trust and the deemed owner of the trust as part of a sale or exchange transaction. This provision may eliminate the benefit of sales to defective trusts created after the date of enactment because gain will be recognized on the sale. If this provision passes, if a taxpayer wants to remove potential appreciation on a particular asset, there will be a cost to do so, as he or she will have to pay the immediate capital gain.
To help navigate the current environment, we have brought in nationally renowned CPA and tax planning expert, Robert S. Keebler, CPA/MST, AEP (Distinguished), CGMA, for a very timely and practical presentation entitled, “How Sales to Grantor Trusts Can Benefit Your Clients in 2023”.
During this 95-minute program, Bob will address the following:
- How Sections 2901 and 1062 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 to avoid the gain issue completely
- 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.
- Program Title: How Sales to Grantor Trusts Can Benefit Your Clients in 2023
- Speaker: Robert S. Keebler
- Duration: 95 minutes
ABOUT THE SPEAKER
CPA/PFS, MST, AEP (Distinguished)
Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished) is a partner with Keebler & Associates, LLP and is a 2007 recipient of the prestigious Accredited Estate Planners (Distinguished) award from the National Association of Estate Planners & Councils. He has been named by CPA Magazine as one of the Top 100 Most Influential Practitioners in the United States and one of the Top 40 Tax Advisors to Know During a Recession. His practice includes family wealth transfer and preservation planning, charitable giving, retirement distribution planning, and estate administration. Mr. Keebler frequently represents clients before the National Office of the Internal Revenue…
IMPORTANT NOTICE REGARDING CE CREDIT
The Ultimate Estate Planner, Inc. and the presenter are not registered Continuing Education Sponsors and this program is not pre-approved for continuing education credit for any state or regulatory agency.
However, please note that each program includes a Certificate of Completion and, depending on the license and the regulatory agency for which governs a participant’s CE credit, some professionals may be able to self-report his or her participation and receive credit. It is the responsibility of the participant to complete any process necessary to seek self-reported CE credit for his or her participation. By registering for a teleconference (or purchasing on On-Demand program), you understand that CE credit is not guaranteed or warranted by the presenter or The Ultimate Estate Planner, Inc.