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Loophole

§453A Interest-Charge Avoidance via Sub-$5M Installment Sales

Stage installment sales under the $5M threshold to skip the §453A deferred-tax interest charge.

Overview

Installment sales over $5M/yr trigger §453A interest charges on the deferred tax. By structuring a large sale as multiple sub-$5M annual tranches (separate assets, separate buyers, or separate tax years), sellers keep 100% installment-sale deferral WITHOUT the punitive interest. Common in multi-parcel real-estate sales and staged business earnouts.

Best fit
Sellers of $5M–$50M assetsReal estate portfolio sellersBusiness owners with earnout structures
Estimated impact
Save 5–8% annually on deferred tax balance

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