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Rolling 2-Year GRATs

Chain short GRATs — any appreciation above ~5% passes gift-tax-free.

Overview

Grantor Retained Annuity Trust: contribute appreciating asset, receive annuity payments back over 2 years equal to contribution + IRS §7520 rate (~5%). Any excess appreciation passes to heirs gift-tax-free. Chain successive 2-year GRATs to capture volatility. Zero downside if asset underperforms (annuity just returns to you).

Best fit
Pre-IPO stock holdersVolatile asset ownersEstate planners
Estimated impact
Transfer $1M–$100M+ appreciation gift-tax-free over 10 years

Click Generate advisory deep dive for mechanics, IRC citations, a step-by-step execution plan, a worked numeric example on your profile, costs, risks, and this-week actions.

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