A grantor creates a Grantor Retained Annuity Trust (GRAT). Which of the following best describes the estate planning benefit?
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A
All trust assets pass free of estate tax regardless of investment performance
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B
If trust assets outperform the IRS Section 7520 rate, the excess passes gift-tax-free to heirs
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C
The grantor receives an income tax deduction equal to the present value of the remainder interest
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D
The trust corpus receives a step-up in basis at the grantor's death