IDGT Swap Power (§ 675(4)(C)) Basis Step-Up Solver

Underwrite exercising grantor substitution powers to swap high-basis cash/notes into an IDGT in exchange for zero-basis appreciated assets to receive a 100% tax-free basis step-up at death.

Appreciated Assets & Tax Basis

Fair Market Value of Low-Basis Assets in IDGT ($ USD)

Original Cost Basis of Assets ($ USD)

Blended Federal + State Capital Gains Tax Avoided (% - e.g. 33.8%)

Tax Savings & Stepped-Up Basis

Immediate Capital Gains Tax Slashed via § 1014 Step-Up

+$3,346,200 Cash Tax Shield

New Stepped-Up Fair Market Tax Basis at Death

$10,000,000 Stepped-Up Tax Basis

Income Tax Triggered on Asset Substitution Swap

$0.00 (Rev. Rul. 85-13: Non-Taxable Swap)