- The
U.S. Government establishes an investment rate of return which
it says you cannot beat. Wealth in excess of this rate can be
transferred to junior family members without causing a taxable
gift or estate tax. The Code Section 7520 rate was 7.4% in October,
2000. The lower the Code Section 7520 rate, the easier it is
to shift tax free wealth to junior family members.
- These
strategies are useful even when your tax free gifting ability
has all been used.
- If
units in a Family Holding Company are used, greater leverage
may be achieved due to discounts, e.g., 7.4% discounted at 35%
equals 4.81%. Therefore, any asset growth in excess of 4.81%
can be removed from your taxable estate tax free.
- Common
methods of achieving this result are with GRATs, GRUTs, SPLATs,
and SPLUTs or sales of remainder interests in property.
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