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A Self-Cancelling Installment Note (SCIN) involves selling an asset for an installment note with a fixed term shorter than the seller's life expectancy, or until death, whichever occurs first. This mortality risk requires compensation through either an increased sale price or higher interest rate. SCIN Advantages: - Avoids gift tax on creation if properly valued - Excludes remaining principal payments from estate tax - Interest may be tax-deductible - Limits payments to original sales price (unlike private annuities) - Useful for GST tax planning when applicable exclusion ($15M) is exhausted But all that glitters is not gold - SCINs have significant disadvantages: 🔗 https://hubs.li/Q040w0W00 Paul Hood provides members with commentary on the Tax Court's decision in Spenlinhauer Est. v. Commissioner, T.C. Memo. 2025-134, examining how post-death administration choices can materially affect estate tax exposure in a case that serves as a lesson in how NOT to arrange a SCIN. #SCIN #EstatePlanning #EstateTax #TaxPlanning
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