The document describes the mechanics of a financial strategy, not a specific transaction. The process involves: 1) A Grantor makes an arm's length sale of assets to an irrevocable trust (IDGT). 2) The Grantor receives a promissory note for the fair market value of the assets plus interest at the current Applicable Federal Rate (AFR). 3) The Grantor pays income taxes on the trust's earnings. 4) Once the note is paid off, the remaining assets pass to the heirs without gift tax.
This document is a confidential presentation slide from J.P. Morgan, identified by the production code 'HOUSE_OVERSIGHT_022351'. It explains the mechanics of an Intentionally Defective Grantor Trust (IDGT) as a tax-efficient strategy for transferring future asset appreciation to heirs. The process involves a grantor selling assets to an irrevocable trust in exchange for a promissory note, allowing the asset's growth to pass to beneficiaries gift-tax-free.
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