授予人保留年金信托基金(GRATs)

Suppose your financial objectives include income and leaving a legacy for your heirs. 在这种情况下, it's essential to work with a financial professional familiar with your many options, 包括旧工具.

Grantor retained annuity trusts (GRATs) gained popularity in 2000 after a favorable ruling by the U.S. 税务法庭向一个从事零售业务的富裕家庭起诉. 这一裁决允许零grat, for which annuity payments return the original assets to the grantor, 只把增值的价值留给受益人. You don't need to be a billionaire to take advantage of a GRAT, which has potential for individuals and families of many income levels.

A GRAT is a financial tool used to reduce taxes on large financial gifts to family members. It involves creating an irrevocable trust for a specific period, 将资产转入信托, 并且每年向授予人支付年金. When the trust expires and the final annuity payment is made, the beneficiary receives the assets with minimal or no gift taxes. GRATs can be a valuable tool for transferring wealth while minimizing gift tax liability. They allow the grantor to move asset appreciation to the remaining beneficiaries, reducing the value of the grantor's assets subject to estate tax. GRAT是为特定年限设立的.

通常, a grantor sets up zeroed-out GRATs for a specific number of years, for which the present value of the annuity stream equals the total value of the property used to fund the GRAT.¹ 这意味着剩余利息的值为0, 从税收的角度来说，这是零价值的礼物. Any assets remaining in the GRAT after the final annuity payment pass to the remainder of the beneficiaries without incurring gift tax.¹

在设置GRAT时, 设保人向信托提供资产, but—this is the crucial part—the grantor retains the right to receive the original value of the assets contributed over the term of the trust, 以及美国国税局规定的回报率. 当信任结束, the remaining assets (the appreciation of the original holdings minus the IRS-assumed return rate) go to the beneficiaries.¹

grat存在风险. 授予人在信托到期前去世的, 这些资产成为他们应纳税遗产的一部分, 受益人什么也得不到. 另外, if the assets depreciate or the IRS's assumed return rate is low, GRAT可能无法提供预期的优势.
GRATs are most useful for individuals with significant estate tax liability, including those who freeze the value of their estate by transferring the appreciation onto their heirs. 例如, if someone expects an asset to grow from $10 million to $12 million over two years, they can transfer the $2 million difference to their heirs without incurring taxes.

GRATs are particularly popular among individuals who own shares in startup companies because the stock price appreciation for IPO shares often exceeds the IRS's assumed rate of return. This allows more money to pass to beneficiaries without affecting the grantor's lifetime exemption from estate and gift taxes.
从所得税的角度来看, the grantor is responsible for the GRAT's income tax liability during the GRAT term. 在这学期剩下的时间里, tax liability can flow through to the grantor or be paid by the trust, 取决于结构.

近年来, 有人提议限制grat的好处, so individuals may want to take advantage of this strategy before any potential legislation passes.

GRAT仍然受欢迎的原因很明显:对许多人来说, these trusts have created a reliable method for minimizing taxes and passing wealth on to future generations. 尽管相对来说比较低调, it remains effective and prevalent among those seeking to sustain their finances.

1. JournalOfAccountancy.2023年9月19日

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