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QPRT |
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If structured properly, the QPRT will freeze the value of the taxpayer's residence at the time he or she creates the trust and result in significant estate tax savings. Even with respect to rather traditional estate tax planning strategies there may be ancillary significant federal tax issues where the law is sufficiently unclear as to bring the advice within their reach, such as when a QPRT or other entity is funded with a fractional interest arguably subject to a discount for lack of marketability. For example, a $3 million residence put into a 15-year QPRT by somebody 55 years old would be valued at about $840,000 for tax purposes, while the same home placed in a 20-year QPRT would be valued at only about $498,000. |
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