The “Walton” Strategy: Zeroed-Out GRATs

The “Walton” Strategy: Zeroed-Out GRATs

Heads I win, Tails I tie. How to transfer stock appreciation to your heirs tax-free with mathematically zero downside risk.

Dec 28, 2025 Code Authority: Team BMT RETIREMENT > LEGACY & ESTATE

Executive Summary

  • The Concept: You put $10M into a GRAT for 2 years. The trust pays you back an annuity equal to $10M plus a small IRS interest rate (7520 Rate, e.g., 4%). If the assets grow at 4%, you get everything back (No harm done).
  • The Arbitrage: If the assets grow at 20%, the trust pays you back the $10M + 4% interest, and the excess 16% growth goes to your children instantly, free of Gift Tax and Estate Tax.
  • “Zeroed-Out”: You structure the annuity payments so that the actuarial value of the “gift” to your children is exactly $0. This means you use none of your Lifetime Exemption. If the stock crashes, the trust simply fails and returns assets to you. You lose nothing but the attorney fees.

The Mortality Risk

The Catch: If you die during the GRAT term (e.g., within the 2 years), the assets claw back into your taxable estate, undoing the strategy. Therefore, successful GRATs are typically short-term (2 years) to minimize the risk of death during the term.

Mechanic: The Hurdle Rate Race

Hurdle Rate
IRS 7520 Rate
Upside
Goes to Heirs
Downside
Returns to You
Gift Tax
$0.00

Simulation: 2-Year GRAT vs. Direct Holding ($10M Tech Stock, 30% Boom)

Wealth Transfer Outcome
Keep in NameEstate Tax Risk Increases
Asset grows to $16.9M. All taxable at 40% later.
GRAT Success$5M Transferred Tax-Free
Grantor gets principal back. Heirs get the $5M profit.
GRAT Failure (Stock Down)No Penalty
Trust dissolves. Assets return to Grantor. Try again next year.
Feature IDGT (Sale) GRAT (Annuity)
Term Long-term / Dynasty Short-term (Usually 2-5 Years)
Interest Rate AFR (Mid/Long-term) 7520 Rate (120% of Mid-term)
GST Exemption Can allocate immediately Cannot allocate until GRAT ends (ETIP)

Volatility is the enemy of investing, but the best friend of a GRAT. A highly volatile stock that pops 50% in one year is the perfect candidate to flush massive value out of your estate for free.”

Essential Resources

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