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Navigating the Generation-Skipping Transfer Tax for FMC Families

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'Thoughtful multigenerational planning can help FMC employees navigate GSTT considerations more effectively, making it an essential part of preparing families for long-term financial transitions.' -- Paul Bergeron, a representative of The Retirement Group, a division of Wealth Enhancement.

'Carefully structuring multigenerational wealth transfers can help FMC employees stay aligned with GSTT rules and should be considered when discussing long-term family planning priorities.' -- Tyson Mavar, a representative of The Retirement Group, a division of Wealth Enhancement.

In this article, we will discuss:

  1. Key concepts behind the generation-skipping transfer tax (GSTT).

  2. Common exemptions and exclusions that may lessen transfer tax exposure.

  3. Planning methods that can help families pass wealth across generations.

Important Takeaways on How to Transfer Wealth Across Generations

The generation-skipping transfer tax (GSTT) is relevant for any FMC employees transferring wealth to grandchildren or other individuals that skip over your children's generation.

Both GSTT and gift or estate taxes may apply when transferring assets to heirs more than one generation below the transferor.

Exemptions may lower transfer tax liability if planning is structured thoughtfully.

Federal gift and estate taxes—applicable to transfers during life or at death—are familiar to many FMC employees. However, when assets move to people more than one generation below the transferor, such as a gift from a grandparent to a grandchild, the federal generation-skipping transfer tax (GSTT) may also apply.

Generation-Skipping Transfer Tax: What Is It?

Transfers to “skip persons,” those more than one generation below the transferor or more than 37½ years younger, are subject to the GSTT. This federal tax applies in addition to any federal gift or estate tax due and equals the highest federal gift and estate tax rate in effect—a flat rate of 40%—which is relevant for FMC employees engaging in multigenerational planning.

The GSTT was introduced in 1976 to address concerns that affluent families could shift assets in ways that bypassed estate taxes at each generational level. 1

Lifetime Exemptions and Gift Tax Exclusions

Transfers made during life or at death to anyone other than a spouse or qualified charity may be subject to federal gift or estate tax. Key exclusions include several that may benefit FMC employees:

Annual gift tax exemption:  In 2026, individuals may give up to $19,000 per recipient without incurring federal estate or gift tax. Couples may combine exclusions for a total of $38,000 per beneficiary. 2  For example, a married couple with two children could give $76,000 total ($38,000 to each child) annually without gift tax.

Qualified transfers:  Payments made directly to educational institutions for tuition or to medical providers for medical expenses are not considered taxable gifts. There is no dollar limit on these transfers. 1

Lifetime unified exclusion:  Individuals may transfer up to $13.99 million (or $27.98 million per married couple) during life or at death without federal gift or estate tax. 2  Lifetime gifts reduce the remaining exclusion available at death.

Transfers exceeding these exclusions are taxed at the top federal estate and gift tax rate of 40%.

Exclusions & Exemptions from GSTT

The GSTT has rules similar to traditional gift tax laws, which can influence planning for FMC families:

  • - Grandparents may give up to $19,000 directly to a grandchild in 2026 without triggering gift tax or GSTT.

  • - Each individual has a $13.99 million lifetime GSTT exemption ($27.98 million per couple), though this exemption is not independent from estate or gift tax rules.

  • Transfers above exemption thresholds are subject to a 40% GSTT.

  • GSTT applies only at the federal level, although some states may impose their own estate or inheritance taxes.

When Does the GSTT Start to Apply?

The GSTT applies to three types of taxable events, all of which may arise in multigenerational planning for FMC families:

Direct skips:  Transfers made directly to a skip person or to a trust for their exclusive benefit. The transferor or their estate pays the tax.

Taxable distributions:  Distributions from a trust to a skip person. The beneficiary pays the tax.

Taxable terminations:  Occur when a trust interest ends and only skip persons remain as beneficiaries. The trustee pays the tax.

GSTT Exemption Allocations

Transfers—outright or to a trust—may qualify for GSTT exemption as long as the exemption is properly allocated. Once allocated, all future growth on those trust assets is generally free from GSTT, a strategy FMC families may want to use.

For example, if a person contributed $10 million to an irrevocable trust for grandchildren in 2024 and allocated the GSTT exemption, and the trust later grew to $20 million, future distributions would not incur GSTT. 1

Methods for Lowering GSTT

1. 529 Plan Contributions

Contributions to 529 college savings plans are treated as completed gifts, even though account owners can change the beneficiary. Grandparents may “superfund” a 529 plan with five years of annual exclusions at once—up to $95,000 per beneficiary in 2025 or $190,000 per beneficiary for a married couple filing jointly 3 —which may interest FMC retirees.

2. Dynasty Trusts

Dynasty trusts are irrevocable trusts designed to last across multiple generations. Some states allow long-term or perpetual trusts, while others limit trust duration under the “rule against perpetuities.” These trusts can combine GSTT planning with long-term asset preservation features and, when fully exempt from GSTT, future distributions or terminations can occur without additional GSTT 4 —an appealing option for extended family planning.

Concluding Remarks

Although GSTT planning can be complex, exemptions and structured transfers may help FMC employees reduce or eliminate federal taxes on wealth passed to grandchildren or other skip persons.

The Retirement Group can assist you with wealth transfer planning and retirement income strategies. Call our team at (800) 900-5867 for guidance.

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Sources:

1. Fidelity Investments. “Understanding the Generation-Skipping Transfer Tax.”  Fidelity , 3 Oct. 2025,  www.fidelity.com/viewpoints/wealth-management/insights/generation-skipping-transfer-tax .

2. Internal Revenue Service. “ IRS releases tax inflation adjustments for tax year 2027 .”  IRS.gov , 9 Oct. 2025.

3. Bendig, Erin. “How This 529 ‘Superfund’ Strategy Can Transform Your Estate Plan.”  Kiplinger , 12 Sept. 2025,  www.kiplinger.com/personal-finance/this-super-529-strategy-can-help-you-jumpstart-college-savings .

4. Investopedia. ' What Is a Dynasty Trust? ' by Will Kenton. 31 March 2025.

How does FMC Technologies plan to manage the investment strategy of its pension plan to ensure it remains solvent and able to meet the benefit payments as employees retire? Given the shifting dynamics of the market, what specific measures is FMC Technologies employing to enhance the liquidity of its assets and mitigate risks associated with underfunding in the current economic climate?

Investment Strategy for Solvency and Benefit Payments: FMC Technologies' pension plan aims to ensure all benefit payments are met as they fall due. The investment strategy includes maintaining funds above the Statutory Funding Objective and transitioning towards lower-risk assets such as Liability Driven Investments (LDI), gilts, and cash. This strategy, driven by advice from LCP, seeks to reduce underfunding risks and ensure liquidity​(FMC_Technologies_Pensio…).

In what ways does FMC Technologies incorporate environmental, social, and governance (ESG) factors into its investment decision-making for the pension plan? How does the commitment to ESG investing align with the broader goals of FMC Technologies, and what impact does it have on the long-term sustainability and performance of the company's pension investments?

ESG Factors in Investment Decisions: ESG factors, including climate change, are considered by FMC Technologies in investment decisions. The company encourages investment managers to integrate ESG considerations into their analysis of future performance and risks. ESG aligns with the long-term sustainability of the pension plan, though there are limited opportunities to apply ESG in the current target investment strategy of LDI, gilts, and cash​(FMC_Technologies_Pensio…).

Can you elaborate on the additional voluntary contribution (AVC) arrangements available through FMC Technologies and how they are designed to support employees in building a more robust retirement income? What choices do employees have within these AVC options, and how can they tailor their investment to suit their individual risk profiles?

Additional Voluntary Contributions (AVC): FMC Technologies provides AVC arrangements designed to offer a range of investment options to help employees build a more robust retirement income. These options allow employees to tailor investments based on their risk-return preferences, ensuring flexibility in achieving personal retirement goals​(FMC_Technologies_Pensio…).

As employees of FMC Technologies approach retirement, what processes are in place to evaluate their pension benefits and determine eligibility for various retirement options? What role does the pension plan's advisory team play in assisting employees with financial planning in preparation for retirement?

Pension Benefits Evaluation Process: FMC Technologies uses a structured process to evaluate pension benefits, supported by investment advisers and trustees. This process involves regularly reviewing the funding level and the benefit cash flows to ensure the pension plan is on track to meet employee retirement needs. Advisory teams help employees with financial planning during the transition to retirement​(FMC_Technologies_Pensio…).

What steps is FMC Technologies taking to transition its investment strategy towards greater exposure to low-risk instruments while still aiming for satisfactory returns? How does this transition align with the company’s funding objectives, and what are the anticipated benefits for the employees in the context of their retirement planning?

Transition to Low-Risk Investments: FMC Technologies has transitioned much of its pension assets into LDI, gilts, and cash to de-risk the investment portfolio. This shift aligns with the company's funding objectives to secure pension liabilities and provide stable returns for retirees. The plan is expected to fully transition to these low-risk instruments to support long-term pension solvency​(FMC_Technologies_Pensio…).

How does FMC Technologies measure the performance of its investment managers, and what criteria are used to evaluate their effectiveness in managing the pension plan's assets? In the event that an investment manager does not perform according to expectations, what procedures are in place for FMC Technologies to reassess and possibly reallocate those funds?

Investment Manager Performance: FMC Technologies evaluates the performance of its investment managers using various criteria, including their ability to meet long-term pension objectives. If an investment manager underperforms, FMC Technologies, with advice from LCP, reassesses and rebalances the portfolio as needed to ensure pension assets are properly managed​(FMC_Technologies_Pensio…).

What communication channels does FMC Technologies recommend employees use if they have questions or need clarification regarding their retirement benefits and the pension plan? How can employees easily access additional resources or support to better understand their retirement options as they transition out of active employment?

Communication Channels for Retirement Benefits: Employees of FMC Technologies can access information and support regarding their pension and retirement benefits through direct communication with trustees and the pension advisory team. FMC Technologies recommends utilizing these resources for clarity on retirement options and to understand the transition out of active employment​(FMC_Technologies_Pensio…).

Considering the implications of portfolio diversification, how does FMC Technologies determine the appropriate asset allocation for its pension plan's investment strategy? What considerations are taken into account to ensure that all employees’ retirement savings are managed in a way that balances risk and growth potential?

Asset Allocation and Portfolio Diversification: FMC Technologies’ pension plan employs a diversified asset allocation strategy, ensuring a balance between growth and risk. The investment strategy considers the need to match liabilities with assets while progressively reducing exposure to high-risk assets like equities and increasing exposure to low-risk instruments like LDI and gilts​(FMC_Technologies_Pensio…).

How does FMC Technologies plan to maintain compliance with regulatory requirements regarding its pension plan, particularly concerning employer-related investments? What are the limitations or restrictions imposed by legislation that affect how FMC Technologies can manage its pension fund assets?

Compliance with Regulatory Requirements: FMC Technologies remains compliant with regulations regarding employer-related investments. Restrictions under the Pensions Act 1995 and the Occupational Pension Schemes (Investment) Regulations 2005 prevent significant investments in TechnipFMC or associated companies to avoid conflicts of interest​(FMC_Technologies_Pensio…).

As risks associated with market fluctuations continue to evolve, how does FMC Technologies plan to adjust its investment strategy to mitigate these risks? What safeguards are put in place to protect retirement benefits during periods of economic uncertainty, and how will these strategies affect the financial well-being of FMC Technologies’ retirees?

Adjusting Investment Strategy for Market Risks: FMC Technologies employs a liability-driven approach to manage the pension fund, mitigating market risks associated with economic fluctuations. Regular reviews of the investment strategy, alongside professional advice, allow the company to adjust and protect the pension plan's assets during uncertain market conditions​(FMC_Technologies_Pensio…).

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.
Pension Plan (Defined Benefit Plan): FMC Corporation has a pension plan known as the "FMC Corporation Employees' Retirement Program." This plan is a traditional defined benefit plan, which provides retirement, death, and disability benefits to eligible employees. The plan's benefits are determined based on years of service and final average pay, which is a common formula used to calculate pension payouts. The plan is primarily available to employees who were hired before July 1, 2007. After that date, new hires were no longer eligible for the defined benefit plan but were instead enrolled in the defined contribution plan. 401(k) Plan: The FMC Corporation Savings and Investment Plan is the company’s 401(k) offering. For employees hired after July 1, 2007, this plan serves as their primary retirement vehicle. FMC contributes a percentage of eligible pay to the plan annually. One of the notable features of this plan is the immediate vesting on all contributions, including the company match. This means that employees have full ownership of all contributions from the outset. The plan offers a wide range of investment options managed by Fidelity Investments.
Restructuring Efforts: FMC Corporation has been actively restructuring its operations to improve efficiency and profitability. The company expects to achieve $50 million to $75 million in adjusted EBITDA contributions from restructuring actions in 2024, with a run-rate savings target of approximately $150 million by the end of 2025. This restructuring is critical for FMC as it navigates through the challenges posed by the global economic environment, including supply chain disruptions and inflationary pressures. Pension and 401(k) Plans: FMC's financial outlook includes maintaining strong adjusted EBITDA and adjusted earnings per share growth, which are key metrics that can influence the stability and benefits of its pension and 401(k) plans. As FMC continues its restructuring and cost-saving measures, these benefits could see adjustments to align with the company’s long-term financial goals.
Stock Options: FMC offers Non-Qualified Stock Options (NSOs), which allow employees to purchase company shares at a predetermined strike price after a specific vesting period. These options align employee incentives with the company's financial performance, as they offer the potential for profit if the company's stock price increases. However, employees must be aware of the risks associated with stock options, including potential forfeiture if they leave the company before the options vest. RSUs: FMC also provides RSUs, which grant employees the right to receive company shares once certain vesting conditions are met. RSUs do not require employees to purchase the shares upfront, making them less risky than stock options. Once vested, the shares are delivered to the employees, and they may choose to sell them, subject to capital gains tax.
In 2023 and 2024, FMC Corporation maintained its commitment to employee health and well-being by continuing to enhance its health benefits offerings. This included expanding mental health resources and increasing flexibility in healthcare spending accounts. Despite economic challenges, FMC has focused on providing robust support for its employees, including coverage for telemedicine services and wellness incentives to promote a healthier workforce.
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For more information you can reach the plan administrator for FMC at , ; or by calling them at .

https://investors.fmc.com/news/news-details/2024/FMC-Corporation-announces-fourth-quarter-and-full-year-2023-results-within-guidance-ranges-provides-2024-outlook/default.aspx https://www.financestrategists.com/retirement-planning/deferred-compensation-plans/ https://www.investopedia.com/terms/n/netunrealizedappreciation.asp https://www.taxfavoredbenefits.com/resource-center/retirement/net-unrealized-appreciation-nua-explained https://pitchbook.com/profiles/company/55527-22 https://www.fidelity.com/learning-center/smart-money/401k-contribution-limits https://www.nerdwallet.com/article/investing/401k-contribution-limits https://www.mercer.com/en-us/insights/retirement/defined-benefit-plans/pension-discount-yield-curve-and-index-rates-in-us/ https://www.foxrothschild.com/publications/interest-rate-hikes-present-challenge-for-fully-funded-pension-plans https://www.milliman.com/en/ https://markets.businessinsider.com/news/stocks/fmc-corporation-to-introduce-strategic-growth-plan-at-investor-day-details-cost-restructuring-and-provides-preliminary-2024-outlook-1032827286 https://www.thelayoff.com/fmc-technologies https://www.kiplinger.com/ https://am.gs.com/en-int/advisors

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