The Income Taxation of IDGT Sale Promissory Notes

An In-Depth Review of the Income Tax Aspects from 3 Key Vantage Points:
During Life, At Death and After Death

One of the most difficult areas of estate planning is the intersection of income tax and estate tax. While many practitioners recognize that the Intentionally Defective Grantor Trust (IDGT) sale is the cornerstone of planning for larger estates, the income tax implications are not as clear as we would like them to be. This area of planning can become very complex as we are forced to define the taxation during the grantor’s life, at the time of the grantor’s death, and after the grantor dies.

This is why we have brought in nation’s leading tax and estate planning experts, Jonathan G. Blattmachr, Esq., and Robert S. Keebler, CPA/PFS, MST, AEP (Distinguished), CGMA., for a very timely and informative presentation entitled, “The Income Taxation of IDGT Sale Promissory Notes During Life, at Death, and after Death”.

In this 92-minute presentation, Jonathan and Bob will cover the following:

• Basis of gifted property and property in death

• The special rules for IRD

• The impact of Section 691(a) of the Code

• How Sections 1014 and 1015 work

• Examining the taxation of IDGT sales during life, as wells as examining the transactions subsequent to death

• A look at the two pivotal cases in the world of IDGTs—what they mean and how they impact the planning we do for clients!

• Planning for the death of the Grantor with ordinary installment notes and with SCINs

• What happens at death when outside debt is greater than the taxpayer’s basis

• A look at some alternative theories adopted by the leading experts, including asymmetrical tax treatment of a basis increase and no gain

• Note basis at death and after death

• Understanding CCA 200923024 and no recognition at death

• Review of  PLR 201245006 which provided for asymmetrical tax treatment

• IRS guidance project outstanding

• And 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.