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Loophole

Zeroed-Out (Walton) GRAT

Transfer appreciation to heirs gift-tax-free with a $0 reported taxable gift.

Overview

A Walton GRAT is structured so the retained annuity equals the §7520 present value of the trust — reporting a $0 taxable gift. Any appreciation above the §7520 hurdle rate passes to heirs completely outside the estate and free of gift tax, using none of the lifetime exemption. Ideal for pre-liquidity founders and volatile-asset holders — infinite upside, zero downside except opportunity cost.

Best fit
Pre-IPO / pre-M&A foundersOwners of appreciating volatile assetsEstate-tax-exposed families
Estimated impact
Transfer $5M–$100M+ gift-tax-free during appreciation event

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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