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Tips From the Pros: Less Giddy About GRATs

Charles A. Redd explores recent Office of Chief Counsel decisions that relate to GRATs.

Grantor retained annuity trusts (GRATs) have been an indispensable component of the estate planner’s toolbox for over 30 years. Internal Revenue Code Section 27021 and Treasury Regulations Section 25.2702-32 set forth the essential framework for a GRAT. When the easy-to-follow GRAT recipe is implemented, and depending on prevailing interest rates, the total return generated by the property committed to the GRAT and whether the GRAT settlor survives the GRAT term, it’s

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