The Private Annuity Trust (PAT) was an effective tool that enabled sellers of appreciated assets to defer taxes due for a number of years. Last Fall, actually on October 18th 2006 to be specific, the IRS proposed regulations ending the use of PAT's as a tax deferral vehicle. Download the proposed Regs. (it's good bedtime reading).
So what options are left? Charitable Remainder Trusts, 1031 Exchanges, Tenents-in-Common (TIC's), traditional installment sales (which the IRS specifically "OK's" in the proposed regs), and the Structured Sale are all viable options, each having respective advantages.
For those individuals that were planning on using a PAT, the Structured Sale provides many of the same tax deferral benefits and is proving to be an effective solution worth reviewing. It is by no means the only tax deferral strategy one should consider. Other strategies are available and may fit a particular situation better. That said, the Structured Sale may become the preferred method used with exit planning strategies. The reason you ask? Well if you didn't then I'm still going to answer. Because it creates a flexible means to defer taxes and guarantee a rate of return on the proceeds (important for retirees) and can also provide a level of asset protection; a combination of attributes that is hard to find. Contact CrailHuntly for information.
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