The Freeze Partnership: A Targeted Solution When GRATs and IDGTs Fall Short

The freeze partnership technique (the “technique”) has been used for decades to transfer wealth to the next generation while reducing estate, gift, generation-skipping and income taxes. Despite being explicitly authorized under Internal Revenue Code (“I.R.C.”) §2701, it remains one of the least utilized estate freeze strategies. By contrast, more familiar alternatives, such as grantor retained annuity trusts (“GRATs”) and installment sales to intentionally defective grantor trusts (“IDGTs”), are... By: Kohrman Jackson & Krantz LLP