Extract to table

The annuity must be a fixed dollar amount or a fixed percentage of the initial fair market value of the trust corpus, determined at the time of the transfer

The annuity must be payable not less frequently than annually

Conversely, a higher § 7520 rate requires larger annuity payments to achieve the same result, but also sets a higher "hurdle rate" that the GRAT assets must exceed in order to generate a wealth transfer to the remainder beneficiary

The valuation discount affects the gift tax computation (reducing the gift tax value of the contributed property), but the annuity must be sufficient to zero out the pre-discount value

If Stonecrest distributions are insufficient to satisfy the annuity obligation in full, the trustee must distribute membership interests in kind or other trust assets to make up the shortfall

The annuity payment structure must accommodate the timing and magnitude of such distributions