QPRT Strategy: Transferring the Family Home at a Discount
Tax Tips / Real Estate Estate
QPRT Strategy: Transferring the Family Home at a Discount
💡 Executive Summary
- Problem: Luxury homes (Primary or Vacation) appreciate rapidly, bloating your taxable estate.
- Solution: A QPRT splits the home into “Right to Live” (Retained) and “Ownership” (Remainder).
- Result: You gift the home to heirs today at a ~50% discount, freeze its value, but keep living in it.
⚠️ THE “RENT BACK” TRAP
When the QPRT term ends (e.g., after 15 years), the home legally belongs to your children. If you want to keep living there, you MUST pay them Fair Market Rent. (This further reduces your estate tax-free!).
When the QPRT term ends (e.g., after 15 years), the home legally belongs to your children. If you want to keep living there, you MUST pay them Fair Market Rent. (This further reduces your estate tax-free!).
For Ultra-HNW families, the Martha’s Vineyard estate or the Aspen ski lodge is not just a home; it’s a tax liability. The QPRT (Qualified Personal Residence Trust) is the specific IRS-sanctioned tool to move these high-value properties out of your estate while you still enjoy them.
🧐 Core Mechanic: The “Time” Discount
The IRS calculates the gift value as: [Current Home Value] minus [Value of Your Right to Live There]. The longer you retain the right to live (e.g., 20 years), the cheaper the gift becomes.
The IRS calculates the gift value as: [Current Home Value] minus [Value of Your Right to Live There]. The longer you retain the right to live (e.g., 20 years), the cheaper the gift becomes.
Performance Simulation
Estate Tax Value ($5M Home, 15 Years)
Keep Until Death (Appreciation)
Taxed on $10.0M
Full Exposure
QPRT Transfer (Frozen & Discounted)
Gift Tax on only $2.5M
75% Shielded
QPRT vs. Direct Gift
| Feature | Direct Gift to Kids | QPRT Structure |
|---|---|---|
| Gift Value | 100% Market Value | ~40-60% Discounted |
| Living Rights | At Kids’ Mercy | Legally Guaranteed |
| Appreciation | Removed from Estate | Removed from Estate |
“The QPRT allows you to give away the house, keep the keys, and pay your children rent in your golden years—moving even more money out of your taxable estate.”
🔗 Related BMT Playbooks (Internal)
🛡️ Sibling Strategy: GRAT (For Stocks/Cash) 📉 Trade-off: Losing Step-up in Basis (Explained) ✅ Metric: IRS 7520 Rate Impact on QPRTs🏛️ Institutional Resources (External)
📜 Legal Text: IRC § 2702 (Special Valuation Rules) ⚖️ Regulation: Treas. Reg. § 25.2702-5 (Personal Residence Trusts) 🏛️ IRS Official: Form 709 Instructions (Gift Tax Return)
BMT designs for tax reality, not theory.