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537 Installment Sale Trust Step-Up in Basis
How the 537 IST interacts with the step-up in basis at death — and what it means for your estate plan.
Why this matters
The step-up in basis is one of the most powerful tools in estate planning: when an asset is inherited, the cost basis is reset to fair market value at the date of death — eliminating the unrealized capital gain for the heirs. Whether and how a 537 IST preserves that benefit is one of the most common questions sophisticated sellers and their advisors ask.
This 6-page memorandum walks through the interaction between the 537 IST structure, IRC §1014, and the practical estate-planning outcomes for families using the strategy.
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