QPRT
Grantor transfers personal residence to irrevocable trust but retains right to live there for a term. Remainder gift tax value is discounted; residence out of estate if grantor survives term.
| Facet | Detail |
|---|---|
| Also called | Qualified personal residence trust |
| A-B / A-B-C role | None |
| When created | During life |
| Revocable | No |
| Inter vivos / testamentary | Inter vivos |
| Typical beneficiaries | Children or heirs receive residence after term |
| Primary purpose | Transfer home at reduced gift tax value |
| Marital deduction | No |
| Uses estate exclusion | Taxable gift is discounted remainder interest |
| In survivor's estate | Back in estate if grantor dies during retained term |
| Basis step-up | Carryover basis to heirs — loss of step-up on lifetime transfer |
| Income tax | Grantor trust during term |
| Crummey powers | No |
| GST / dynasty | If remainder to skip persons |
| Spendthrift | For remainder beneficiaries |
| See-through (IRA) | N/A |
| Key tradeoff | Gift tax discount vs mortality risk and loss of step-up |