Aals iconAalsSep 26, 2026

WSJ: The IRS Is Cracking Down on a Favorite Way the Ultrawealthy Pass On Money

Grantor retained annuity trusts (GRATs) are a longstanding staple of high-end estate planning.

WSJ: The IRS Is Cracking Down on a Favorite Way the Ultrawealthy Pass On Money

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Grantor retained annuity trusts (GRATs) are a longstanding staple of high-end estate planning.

The basic structure is well-traveled: a grantor transfers appreciating assets to an irrevocable trust, retains an annuity for a fixed term, and—if the assets outperform the rate on the annuity—shifts excess...

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The useful part

Grantor retained annuity trusts (GRATs) are a longstanding staple of high-end estate planning. The basic structure is well-traveled: a grantor transfers appreciating assets to an irrevocable trust, retains an annuity for a fixed term, and—if the assets outperform the rate on the annuity—shifts excess appreciation to beneficiaries with comparatively little gift-tax cost.

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The basic structure is well-traveled: a grantor transfers appreciating assets to an irrevocable trust, retains an annuity for a fixed term, and—if the assets outperform the rate on the annuity—shifts excess appreciation to beneficiaries with comparatively little gift-tax cost.

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