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§453 Installment Sale to IDGT

Sell appreciated assets to your grantor trust — freeze estate, defer gain.

Overview

Sell appreciated business/real estate to an Intentionally Defective Grantor Trust for a promissory note at AFR (~4.5%). No gain recognized (grantor sells to himself for tax purposes). Trust holds the appreciating asset outside your estate; you hold a fixed-value note that gets consumed. Freezes estate value, transfers all future appreciation to heirs.

Best fit
$5M+ estatesBusiness/RE owners with appreciationMulti-gen planners
Estimated impact
40% estate tax elimination on all future appreciation

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