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Using quantitative analysis, we’ll show that the grantor’s choice is almost always clear: If her two-year GRAT is funded with marketable securities and is underwater at all prior to the first annuity date, she should cut her losses and start a new GRAT. That is, no matter the Internal Revenue Code Section 7520 rate, even if her GRAT is underwater by just 2 percent prior to the first annuity date, her GRAT will almost certainly fail, and even in the unlikely event that it doesn’t fail, re-GRATing yields superior results in nearly all instances.

Article here.