537 Installment Sale Trust Legal Memorandum
The full legal foundation for the 537 IST strategy — IRC §453, Publication 537, and the constructive-receipt doctrine.
About this memorandum
The 537 IST is built on three pillars of U.S. tax law: IRC Section 453 (the installment-sale method), IRS Publication 537 (the official taxpayer guide to installment sales), and the long-established constructive-receipt doctrine. This memorandum walks through how the 537 IST structure satisfies each, citing the relevant code sections, regulations, and case law.
It is intended for tax advisors, attorneys, CPAs, and sophisticated sellers who want to verify the legal underpinnings of the strategy before recommending or proceeding with a 537 IST.
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