hard · Certified Financial Planner Estate Planning

Abramson, age 66, holds a liquid net worth of $4,000,000, which includes a $1,200,000 concentrated position in a utility stock with a cost basis of $110,000. He is interested in 'zeroing out' future estate taxes and asks for a recommendation on establishing a five-year Grantor Retained Annuity Trust (GRAT) to move the stock's future appreciation to his heirs.

Given that the 2026 Basic Exclusion Amount is $15,000,000, what is the most appropriate recommendation?

  1. Execute a private annuity sale to the heirs to remove the asset from the gross estate immediately.
  2. Diversify the utility stock first into an S&P 500 index fund before funding the GRAT to reduce risk.
  3. Immediately fund a five-year zeroed-out GRAT to capture appreciation above the Section 7520 rate.
  4. Retain the stock in the taxable account to ensure a full basis step-up at death under Section 1014.

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