Sales to IDGTs
Can Be Both Powerful and Risky
(Unless You Do Them Right)!
For your high net worth clients, sales to “IDGTs” (Intentionally Defective Grantor Trusts) can be a tremendously leveraged, highly beneficial estate tax strategy - - if they’re done correctly.
Whether you have already used this planning technique or are considering using it, you need to understand the pros, cons, and risks - - particularly in light of the Woelbing case and increased IRS scrutiny.
You need to know how to:
- Assure Grantor Trust status
- Balance bet-to-live and bet-to-die strategies
- Structure IDGT sales to avoid IRC Sections 2701, 2702, and 2036 (and the Woelbing case)
- Hedge sales to IDGTs with SCINs (including the truth about the “9 to 1 ratio”)
- Design note sales
- Use guarantees
- Apply Rev. Rul. 93-12 when your client has more than one child
- Draft protective clauses for revaluation based on the Wandry, Petter, McCord, and Christianson cases
- Design QTIP, GRAT, and LPA overflow clauses
Join us and Robert Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA for a 90-minute presentation entitled, “Sales to Grantor Trusts - - Revisited”.