Intentionally Defective Grantor Trust (IDGT)
What is an IDGT?
Why is an IDGT considered “defective”?
How do you plan with an IDGT?
Why might someone create an IDGT?
- valuation discounts
How do you create an IDGT?
You need to structure an IDGT to avoid
- IRC 2701
- IRC 2702
- IRC 2036
- Woelbing case
You can structure an IDGT with a SCIN.
What should the length of the note be?
What is the 9 to 1 ratio?
How do you apply Rev. Rul. 93-12 when a client has more thna one child?
Explain the following cases re revaluation and propose protective clauses:
- Wandry
- Petter
- McCord
- Christianson
How do you design QTIP, GRAT, and LPA overflow clauses?
Choosing a Situs
Using Guarantees
What tax issues are related to IDGTs?
How is grantor trust status triggered?
Why is an IDGT good in a low interest environment?
When might it be better to use a non-grantor trust?
Are there any proposed changes to IDGTs rules?