
This estate planning move makes every other strategy look basic.
It’s called the Installment Sale to an Intentionally Defective Grantor Trust (IDGT) - and despite talk of it being eliminated, it’s still alive and well.
Quick breakdown:
- You seed a trust with a chunk of your lifetime exemption (say $30M).
- You then sell up to 10x that amount ($300M) to the trust using an installment note.
- The note “locks in” your estate’s value - all future growth escapes estate tax.
- Because it’s a grantor trust, you cover its taxes personally, quietly reducing your estate even more.
Downside? No step-up in basis at death.
Fix? Swap the appreciated assets back into your estate before you die (often using borrowed cash). The assets qualify for step-up, but your estate value doesn’t actually rise.
Throw in valuation discounts on business interests gifted in minority slices - and you’ve got one of the most tax-efficient structures ever designed.
Truly next-level stuff.