Tax Strategies for the Wealthy: Qualified Personal Residence Trust (QPRT)

Wealth management is an important issue for thoseto pay trust expenses, mortgage payments, or
with substantial assets to protect. Many peopleimprovements within the next six months. While
incorrectly assume that their estates will escapeexpenses may be paid from the trust, it will generally
federal estate tax as a result of underestimating whatbe easier for you to pay them directly. The trust is
their principal residence will be worth when they die.permitted to hold insurance on the property, as well as
Often, our homes are our most valuable assets. Theany proceeds as a result of damage to the residence
Qualified Personal Residence Trust (QPRT) provides athat are intended to be used for repair or replacement.
means for significantly reducing the estate taxThe proceeds must be held in a separate account.
consequences of the family home and one vacationIf you intend to continue residing in the residence after
home. The QPRT also provides an excellent assetthe trust expires, a fair market value rental will have to
protection vehicle since you no longer own thebe paid to the children to avoid estate inclusion.
property once the trust is established.How do I Terminate a QPRT?
The following is a summary of the benefits andIf the term of the trust expires during your lifetime, the
features of a Qualified Personal Residence Trust.residence will pass from the trust to the remainder
What is a Qualified Personal Residence Trust?beneficiaries. The terms of the trust can state that you
A QPRT is an irrevocable trust created by thehave the right to rent the residence. IF you fail to
Grantor (yourself) for your own benefit. The Grantorsurvive the term of the trust, the trust will end. Your
transfers a primary or secondary residence into theinterest in the QPRT will be includable in your estate.
trust and retains the continued right to use theYour estate would get credit for any gift tax that had
residence for the term of the trust. You, as Grantor,been paid.
select a term of years that the trust will exist. AfterWhat are the Tax Consequences of a QPRT?
the trust ends, the residence will pass to the namedThe advantage of the QPRT is the reduced estate
trust beneficiaries.and gift taxes on the gift of the property. The transfer
How is a QPRT established?of the residence to the trust is subject to gift tax and
A formal appraisal should be obtained to substantiatewill consume the unified credit to the extent of the
the value of the residence on the date of transfer totaxable gift. A gift tax return will be required no matter
the trust. The Grantor makes a taxable gift to thehow small the remainder is because it will not qualify
trust. The taxable gift is the fair market value of thefor the annual exclusion. However, the taxable gift will
transferred residence reduced by the value of thebe significantly less than the value of the property,
interests retained by the grantor. Because thesince the taxable gift is only a percentage of the value
remainder is a future interest, it will not qualify for theof property transferred to the QPRT based on your
$10,000 annual exclusion. The taxable gift will beage and the terms of the trust.
determined by using the actuarial tables in IRSThe full value of the trust assets are exempt from
Publication 1457 to value the remainder, taking intoestate tax if you survive the term of the trust. The full
account the two values retained by the grantor, i.e. (i)value of the trust assets are taxed in your estate if
the right to income for the term of the trust, and (ii) theyou fail to survive the term of the trust.
right to receive the property back if the grantor diesAll income and deductions are reported to you, as
during the trust term. The table determines the rate bygrantor. A separate income tax filing is not required if
taking into account the term of the trust and your ageyou are also the trustee. Your children, as remainder
at the time of the gift to the trust.beneficiaries, will receive a basis in the property equal
How is a QPRT Operated?to your basis in the property.
The trust document must prohibit the sale of theCalifornia does not impose a property transfer tax
residence held in the trust to the Grantor, thewhen a QPRT is established because it is a gift
grantor’s spouse, or any entity controlled by eithertransaction. Recording fees for the new deed will be
of them. The trust should also be prohibited fromimposed.
holding any asset other than a residence used by theAs an example, if the residence is valued at $1,000,000
Grantor as a personal residence. Personal property,and you transfer the property to the QPRT at age 60,
such as furnishings, may not be held in the trust. Thefor a term of ten years, the following will result:
document must require that net income be distributedProperty Value                            
annually to the grantor. The document may permit the$1,000,000
sale of the residence and may permit the trust to holdGrantor Age                                
proceeds from the sale of the residence, in a separate60 years
account.Trust Term                                
You, as Grantor, will have unlimited access to and use  10 years
of the residence. You have the right to occupy theFederal Rate                             
property, have guests join you at the property, receive   8%
the rental income if the residence is rented to thirdValue of Taxable Gift                   
party persons, and sell and purchase other substitute$377,565
property. You are responsible for paying all expensesValue of Retained Interest             $622,435
relating to the property.The values would obviously change as any factors
Cash additions may be held in a separate account inchange.
an amount that does not exceed the amount needed