The “Buy, Borrow, Die” Strategy: How to Live Tax-Free on Debt

The “Buy, Borrow, Die” Strategy: How to Live Tax-Free on Debt

โœ๏ธ By Team BMT (CPA) | ๐Ÿ“… Updated: Dec 18, 2025 | โš–๏ธ Authority: IRC ยง 1014 (Step-Up in Basis) / Edward McCaffery (Tax Law Professor)
* Note: This analysis is written within the U.S. institutional investment framework. All examples, tax considerations, and instrument implementations reflect the structure of the U.S. capital markets (specifically Regulation T and SBLOC).

๐Ÿ“œ WHO THIS IS FOR (Prerequisites)

  • Required Profile: Ultra-High-Net-Worth Investors ($5M+ Taxable Assets) holding highly appreciated assets.
  • Primary Objective: Liquidity Access without Taxation (Monetizing wealth without triggering a taxable sale).
  • Disqualifying Factor: Investors with small portfolios (where loan rates are high) or those heavily invested in retirement accounts (cannot be used as collateral).

โš ๏ธ STRATEGY ELIGIBILITY CHECK

Leverage is a double-edged sword. This strategy requires strict Loan-to-Value (LTV) discipline.

  • โ˜‘๏ธ Asset Type: Must hold assets in a Taxable Brokerage account. (401k/IRA assets are legally barred from being pledged as collateral).
  • โ˜‘๏ธ LTV Buffer: Should borrow no more than 30-40% of the portfolio value to withstand a 50% market crash without a margin call.
  • โ˜‘๏ธ Rate Sensitivity: Must be able to service floating-rate interest payments (SOFR + Spread).
  • โ˜‘๏ธ Exit Plan: Must intend to hold the assets until death (Step-Up in Basis) to wipe out the tax liability permanently.

*Warning: If you are forced to sell during a market crash to cover the loan, you trigger both capital losses and tax bills simultaneously.

EXECUTIVE SUMMARY

  • The Dilemma: You have $10M in Apple stock with a $100k cost basis. You need $1M cash. Selling triggers ~$2.4M in taxes (Federal + NIIT).
  • The Strategy: Instead of selling, you pledge the stock as collateral for a Securities-Based Line of Credit (SBLOC). You borrow $1M.
  • The Mechanism: Borrowed money is not taxable income. You pay 0% tax on the $1M cash. You pay interest on the loan, which is often lower than the tax hit.
  • The “Die” Part: When you pass away, the cost basis of the stock “steps up” to the market value at death. Your heirs sell the stock tax-free to pay off the loan and keep the difference. The capital gains tax is never paid.

For the middle class, debt is a liability. For the ultra-wealthy, debt is a tax shelter. “Buy, Borrow, Die” is the mathematical exploitation of the fact that the U.S. tax code taxes realization (selling), not wealth. Source: ProPublica Analysis / USC Law School

๐Ÿ“Š MODEL METHODOLOGY & ASSUMPTIONS
  • Scenario: Need $1,000,000 Cash from a $5M Portfolio.
  • Cost Basis: Near zero (highly appreciated).
  • Tax Rate: 23.8% (Federal LTCG + NIIT). State tax excluded.
  • Loan Rate: Assumed 6% (SOFR + Spread for HNW).
  • Comparison: Selling Stock vs. Borrowing against Stock.

Cost of Capital Comparison ($1M Liquidity)

Strategy Immediate Tax Cost ($) Total Cost (Year 1)
Sell Assets (Trigger Tax) 238000 238000
Borrow (SBLOC @ 6%) 0 60000

*Chart Note: Selling forces a 23.8% immediate “haircut” on your wealth. Borrowing costs only 6% (interest). Unless the loan drags on for many years or rates skyrocket, borrowing preserves significantly more capital.

Structural Comparison Matrix

*Not all debt is created equal. SBLOCs differ significantly from standard margin.

Feature Standard Margin Loan SBLOC (Line of Credit)
Purpose Buying more stock (Leverage) Personal Liquidity (Real Estate, Lifestyle)
Use of Proceeds Restricted to securities Unrestricted (Anything except buying stock)
Interest Rates Often High (Retail Rates) Institutional Pricing (SOFR + Low Spread)
Tax Deductibility Inv. Interest Expense (Sched A) Generally Non-Deductible (Personal Use)

*Operational Note: SBLOCs are “Non-Purpose” loans. You cannot use the proceeds to buy more securities (Reg U violation), but you can buy a house, a boat, or pay taxes.

Strategic Mechanics: The “Step-Up” Reset

The Final Act: Why the tax is never paid.

  • Scenario: You borrowed $1M against $5M of stock. You die with the loan outstanding.
  • Estate Settlement:
    1. Portfolio Value: $5M.
    2. Cost Basis: Resets to $5M (Date of Death).
    3. Heirs sell $1M of stock to repay the bank.
    4. Tax Calculation: Sale Price ($1M) – New Basis ($1M) = $0 Gain.
  • Verdict: The loan is repaid with tax-free proceeds. The IRS gets nothing on the appreciation.

โ›” BOUNDARY CLAUSE: Structural Limitations

  • Interest Rate Risk: In a high-rate environment (e.g., rates > 8%), the cost of borrowing may exceed the expected return of the portfolio. If the loan interest compounds faster than the portfolio grows, you erode wealth.
  • The “Maintenance Call”: If the market crashes and your LTV breaches the limit (usually 50-70%), the bank will force-sell your assets at the bottom. This triggers the worst possible outcome: Loss of Principal + Unexpected Tax Bill.

๐Ÿ‘ค DECISION BRANCH (Logic Tree)

IF Portfolio < $1M or "Core" Retirement Funds:
โ€ข Input: High rates, limited negotiation power, risk aversion.
โ€ข Output: Avoid SBLOC. The risk of a margin call wipes out the benefits.

IF Portfolio > $5M (Taxable) & Low Basis:
โ€ข Input: Access to institutional rates (SOFR + 1.5%); Huge unrealized gains.
โ€ข Output: Execute Buy, Borrow, Die. Borrow for short-term needs instead of selling. Keep LTV below 30%.

“Buy, Borrow, Die” is not essentially about debt; it is about “Asset Inertia.” It allows the compounding engine to run uninterrupted by tax events, using the bank’s balance sheet to fund your lifestyle.

Disclaimer: This content is for educational purposes only. Leveraging assets involves the risk of losing more than the original investment. Lenders can sell pledged assets without notice to satisfy a maintenance call. Interest rates are floating and can increase costs significantly.