GRATs and QPRTs
Freeze-and-shift techniques under IRC 2702: zeroed-out GRATs, mortality risk, and qualified personal residence trusts.
What this guide covers
- IRC 2702 zeroes out non-qualified retained interests; GRATs and QPRTs use qualified interests to shift appreciation cheaply.
- Zeroed-out, short, laddered GRATs suit volatile assets and low 7520 rates; mortality during the term causes estate inclusion.
- QPRTs benefit from higher 7520 rates and longer terms; the grantor must pay rent after the term.
- GRATs are weak GST tools due to the ETIP rule — use other vehicles for generation-skipping goals.
The full guide includes the detailed analysis, worked examples, statutory citations, and related resources below.
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Educational reference, not legal advice. Prepared for licensed professionals as general reference; not legal advice and no attorney-client relationship is created. Law varies by state and changes over time — verify transfer-tax figures and statutory citations against current primary authority. This resource was last updated 2026-07-31. Estateur is not a law firm.