Other People's Money
Back to library
Loophole

Installment Sale to Intentionally Defective Grantor Trust

Freeze estate value at today's price; all future growth escapes estate tax.

Overview

Sell appreciating assets (business interests, real estate, pre-IPO stock) to an IDGT in exchange for a long-term promissory note at the AFR. Because the trust is 'defective' for income tax (grantor pays the tax) but respected for estate/gift purposes, all future appreciation compounds inside the trust — outside the estate. Combined with valuation discounts, this is the workhorse estate-freeze technique for $10M+ estates.

Best fit
Business owners with $10M+ appreciating equityReal estate portfolio ownersPre-liquidity founders
Estimated impact
Freeze $10M–$500M+ of future appreciation outside estate

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.

More loophole strategies

See all Loophole strategies
OPM