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Grantor Deemed Owner Trust

Thomas contributes $1 million of assets to a Family Limited Partnership.
Thomas receives General Partnership and Limited Partnership units in return for this contribution.
Thomas makes a gift of Limited Partnership units to the Grantor Deemed Owner Trust to give the trust viability to enter into future transactions.
Thomas sells the Grantor Deemed Owner Trust the remaining Limited Partnership units.
The trust purchases the remaining Limited Partnership units by providing Thomas with an interest-only note for the purchase price. The interest on the installment sale provides Thomas continued current income.
The Trustee of the GDOT purchases a second-to-die insurance policy on Thomas and his wife.
The trust pays for the insurance policy with excess funds generated by the Limited Partnership.
The corpus of the GDOT, including the life insurance policy or death benefits, pass to the children per terms of the trust.
U.S. Treasury Circular 230 requires that this firm advise you that any tax advice provided was not intended or written to be used, and cannot be used by you, for the purpose of avoiding penalties that the IRS could impose upon you.