GRAT and IDGT sale
Both structures freeze the estate at today’s value and pass future growth to the family. A GRAT gives the grantor an annuity for a term; a sale to an intentionally defective grantor trust takes back a note at the AFR. One is cheap but needs survival, the other is larger but needs a real sale.
| Measure | GRAT | IDGT sale |
|---|---|---|
| Amount transferred | $5,000,000 | $5,000,000 |
| Gift at the outset | $2,972,276 | $500,000 |
| Paid back to the grantor | $2,500,000 | $7,000,000 |
| Value outside the estate | $7,172,984 | $3,604,257 |
| Stays in the estate | $0.00 | $5,000,000 |
| Gift tax | $1,188,910 | $200,000 |
| State gift tax | $0.00 | $0.00 |
| GST | $0.00 | $0.00 |
| Net to family | $5,984,074 | $3,404,257 |
| Leverage | 2.41× | 7.2× |
| Survival risk | Assets return to the estate | None: the sale is complete |
A GRAT is a bet on the grantor surviving the term; the sale to a defective trust is not. That is why the GRAT is usually cheaper and the sale usually larger.
V − annuity · a(n, r) · Zero when the annuity is V / a(n, r).
V(1+g)ⁿ − annuity · ((1+g)ⁿ − 1)/g · Growth above the hurdle.
sale price · AFR · Interest-only, balloon at maturity.
trust value − note principal · What the assets earned above the note.
A clear path from inputs to results.
Both structures freeze the estate at today’s value and pass future growth to the family. A GRAT gives the grantor an annuity for a term; a sale to an intentionally defective grantor trust takes back a note at the AFR. One is cheap but needs survival, the other is larger but needs a real sale.
How to use
- Choose the GRAT or the sale to a defective trust.
- Enter the assets transferred and the term.
- Set the §7520 rate or the AFR — the hurdle the assets must beat.
- Set the return you expect the assets to earn.
- For a GRAT, set the annuity; for a sale, set the seed gift and any grantor tax paid.
The formula
Reference: IRC §2702 (retained interests), §7520 (valuation); the AFR is published monthly under §1274.
Worked example
$5m GRAT against a $5m sale, 10 years, 8% return
- Assets worth $5,000,000, term 10 years, §7520 rate 4%.
- GRAT annuity 5% a year, survival probability 97%.
- Sale with a 10% seed gift, note at 4%, grantor pays $60,000 of income tax a year.
- Expected return 8% in both cases.
- 1
The GRAT pays $250,000 a year, which is below the zeroed-out $616,455, so it carries a $2.97m gift.
- 2
The trust grows to $10.79m and pays back $2.5m, leaving $7.17m for the family — 2.41× the gift.
- 3
The sale's note costs $200,000 a year in interest; the assets still grow to $10.79m.
- 4
After repaying the $5m note and crediting the tax payments, $3.60m sits outside the estate for a $500,000 seed gift: 7.2×.
- 5
Transfer tax avoided: $2.87m on the GRAT, $1.44m on the sale.
GRAT gift $2.97m, remainder $7.17m · sale transfers $3.60m for a $0.5m gift.
Interpreting the result
The GRAT is the cheaper structure because the annuity is a retained interest, not a gift — but it is a bet on survival, and if the grantor dies inside the term the assets come back into the estate. The sale transfers more per dollar of gift because the note is repaid at the AFR rather than at the hurdle, but it needs a genuinely independent trustee and a properly serviced note.
Assumptions & limitations
- A single contribution, a fixed term and a constant total return.
- The GRAT remainder is weighted by the probability the grantor survives the term.
- The sale uses interest-only payments with a balloon at maturity; the note stays in the estate.
- Federal transfer tax at 40%; no GST, no state tax and no income tax on the note interest.
Frequently asked questions
What is a zeroed-out GRAT?
One where the annuity is set so the remainder has no value at the §7520 rate, so the gift is essentially zero. Everything above the hurdle passes to the family free of gift tax.
Why use a defective trust rather than a plain one?
Because a grantor trust lets the grantor pay the trust's income tax, which is an additional tax-free gift and lets the trust compound faster. That is the 'defective' part, and it is deliberate.
Why is the GRAT a bet on survival?
Because the grantor must outlive the term. If they die inside it, some or all of the trust is pulled back into the estate and the freeze fails.
How large should the seed gift be?
Around 10% of the sale price is the usual comfort level: enough that the trust has real equity, small enough to use little exemption.
Methodology last reviewed 2026-10-21. Results are informational and not financial or engineering advice — see our disclaimer.