An 'arm's length sale of assets' from a Grantor to an Intentionally Defective Grantor Trust (IDGT). In exchange, the Grantor receives a promissory note for the fair market value of the asset plus interest at the current Applicable Federal Rate (AFR). The Grantor is also responsible for paying income taxes generated by the trust's assets. The trust should be 'pre-funded' to cover the note.
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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