Intra-Family Transactions in Estate Planning: Structuring Loans and Self-Cancelling Installment Notes

Strategies to Minimize the Gift Tax and Avoid Inclusion in the Gross Estate

Recording of a 90-minute CLE webinar with Q&A

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Conducted on Tuesday, June 23, 2015

Recorded event now available

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Course Materials

This CLE course will guide estate planning counsel in the use of intra-family transactions for wealth shifting and preservation. Attendees will learn techniques and approaches to minimize gift tax consequences and avoid inclusion in the gross estate.


Given the current low interest rate environment and many grantors’ desire to assist family members financially during their lives while shifting and preserving wealth, intra-family loans and self-cancelling installment notes are important estate planning tools.

Since the IRS subjects intra-family loans to tough scrutiny, counsel must carefully structure these transactions to maintain favorable tax treatment. Estate planning attorneys must develop a deep understanding of the IRS requirements and red flags to shield the transaction from being deemed a disguised gift.

Attendees will learn how family entities can operate as “family banks” to achieve family objectives. Counsel must also be proficient in structuring self-cancelling installment notes. Alternatives to these techniques will be discussed as well.

Listen as our experienced panel provides guidance on how to structure intra-family transactions for wealth preservation and shifting. The panelists will discuss intra-family loans and self-cancelling installment notes, and provide best practices for maintaining tax advantages and avoiding pitfalls that can render these transactions as taxable gifts or includible in the grantor’s estate.



  1. Loan/note background
  2. Self-cancelling installment notes (SCINs)
  3. Alternatives to intra-family loans and SCINs


The panel will review these and other key issues:

  • What types of intra-family transactions are available to a grantor who wishes to assist family members financially while preserving wealth?
  • How should counsel structure an intra-family loan to avoid IRS categorization as a disguised gift?
  • How can trusts, family entities and individuals serve as “family banks”?
  • Can existing loans be refinanced?
  • What types of state law issues are implicated in intra-family loans?
  • What considerations should be made in structuring self-cancelling installment loans?


Kathryn Baldwin Hecker
Kathryn Baldwin Hecker

Arnall Golden Gregory

Ms. Hecker focuses her practice on complex wealth transfer planning, including federal and state wealth transfer...  |  Read More

Tippett , Scott
Scott K. Tippett

The Tippett Law Firm

Mr. Tippett's practice focuses on wealth law, as a comprehensive and integrated approach to domestic and...  |  Read More

Michael L. Van Cise
Michael L. Van Cise

Arnall Golden Gregory

Mr. Van Cise focuses his practice on sophisticated wealth transfer planning, federal and state wealth transfer...  |  Read More

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