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§7872 Below-Market Family Loans

Loan family at AFR (~4.5%), they invest at 8%+, spread grows outside your estate.

Overview

Loan large sums to children, grandchildren, or their trusts at the Applicable Federal Rate (~4.5% long-term as of 2024). They invest in real estate, business, or markets earning 8–15%. The arbitrage spread compounds in their hands, outside your estate. No gift tax on properly documented notes. Combine with GRATs and IDGTs for compounded transfer.

Best fit
High-net-worth parentsGrandparents funding trustsEstate freeze planners
Estimated impact
3–10% annual estate-tax-free wealth transfer to heirs

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