The Great GRAT Bailout

We say that a grantor retained annuity trust that outperforms the Internal Revenue Code Section 7520 rate will succeed; in other words, it will transfer property in a tax-efficient manner. Conversely, we say that a GRAT that fails to outperform the rate will fail. But like much that is commonly said, this accepted wisdom is at best an oversimplification. However, it is not an oversimplification to

We say that a grantor retained annuity trust that outperforms the Internal Revenue Code Section 7520 rate will succeed; in other words, it will transfer property in a tax-efficient manner. Conversely, we say that a GRAT that fails to outperform the rate will fail. But like much that is commonly said, this accepted wisdom is at best an oversimplification. However, it is not an oversimplification to note that GRATs are extremely sensitive to investment.1,2

So, back in the goo

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