Sales to Grantor Trusts – In a Low Interest Rate Economy - 2020 Update
Sales to grantor trusts can be very beneficial for your clients, if done correctly. There are various ways to structure this transaction, each having its own pros and cons. Find out which structure is best for your client in today’s tax and economic environment.
During this session the following topics will be covered.
o Assuring grantor trust status
o Taking advantage of our low interest rates
o Choice of Situs
o Balancing bet-to-live and bet-to-die strategies
o Intentionally Defective Grantor Trust (IDGT) strategies including
o Designing the “tax-burn” and the “tax-burn SCIN”
o Sales to IDGTs
o Structuring IDGT sales to avoid Sections 2701, 2702 and 2036 (and the Woelbing case)
o Sales to an IDGT with a SCIN hedge
o How to design note sales to assure debt treatment
o Choosing the length of notes
o The truth about the 9 to 1 ratio
o The use of guarantees
o Applying Rev. Rul. 93-12 when your client has more than one child
o Protective clauses for revaluation including the Wandry, Petter, McCord, and Christianson cases
o Designing QTIPs, GRATs, and LPA overflow clauses
o Audit proofing your design and gift tax returns
There will be no CE for this webinar
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