Understanding the Intentionally Defective Grantor Trust (IDGT) and Its Benefits

Definition & Meaning

An intentionally defective grantor trust (IDGT) is a specific type of irrevocable trust where the grantor retains significant control over the trust's assets. For income tax purposes, the trust is treated as if it is the same entity as the grantor, meaning any income generated by the trust is taxable to the grantor. However, for estate tax purposes, the trust is considered separate from the grantor's estate. This dual treatment arises because the trust is designed to intentionally violate certain grantor trust rules set forth in the Internal Revenue Code, specifically sections 671 to 677. Despite the grantor's tax obligations, the trust's assets are not included in the grantor's estate for estate tax calculations.

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Real-world examples

Here are a couple of examples of abatement:

Example 1: A wealthy individual establishes an IDGT to transfer ownership of a family business to their children while retaining control over the business operations and tax liability. This allows the grantor to manage the business without it being included in their estate for tax purposes.

Example 2: A person sets up an IDGT to hold real estate investments. They continue to pay taxes on the income generated by the trust while ensuring that the properties are not subject to estate taxes upon their death. (hypothetical example)

Comparison with related terms

Term Definition Key Differences
Grantor Trust A trust where the grantor retains certain powers, making the income taxable to them. IDGTs are intentionally defective for tax purposes, while grantor trusts may not be.
Irrevocable Trust A trust that cannot be modified or terminated by the grantor. IDGTs are a type of irrevocable trust specifically designed for tax strategies.

What to do if this term applies to you

If you are considering setting up an IDGT, it is advisable to consult with an estate planning attorney who can provide personalized guidance. You can also explore US Legal Forms for templates and resources to help you create an IDGT that meets your needs. If your situation is complex, professional legal assistance may be necessary to navigate the intricacies of tax law and estate planning.

Quick facts

  • Type: Irrevocable trust
  • Tax treatment: Taxable to the grantor for income tax, separate for estate tax
  • Key benefit: Minimizes estate tax liability
  • Legal framework: Internal Revenue Code §§ 671"“677

Key takeaways

Frequently asked questions

The main purpose is to transfer wealth to beneficiaries while minimizing estate tax liability.