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How 3M Employees Can Use Intentionally Defective Grantor Trusts (IDGTs) in Estate Planning

Healthcare Provider Update: Healthcare Provider for 3M: 3M does not directly provide healthcare services but has a significant stake in the healthcare sector through its Health Care business, which will operate as Solventum following its spin-off. Solventum focuses on various healthcare innovations, including medical devices, pharmaceuticals, and health information systems, positioning itself as a critical player in improving patient outcomes and healthcare delivery. Potential Healthcare Cost Increases in 2026: As the healthcare landscape faces an impending crisis, projections indicate that healthcare costs may surge significantly in 2026, with some states expecting premium hikes surpassing 60% - primarily as a result of the potential expiration of enhanced federal subsidies for ACA plans. This situation, compounded by rising medical costs and aggressive rate increases from leading insurers, could lead to a staggering average out-of-pocket premium increase of 75% for 92% of marketplace enrollees, making affordable healthcare increasingly elusive for millions. Stakeholders will need to navigate these changes carefully to mitigate financial impacts on consumers. Click here to learn more

“3M employees reviewing IDGTs can benefit from understanding how these trusts may support long-term legacy planning, although qualified legal and tax professionals should review these strategies to determine whether they fit into their overall goals.” ~ Wesley Boudreaux, a representative of The Retirement Group, a division of Wealth Enhancement.

“3M employees considering an IDGT should recognize how this strategy may support long-term wealth transfer goals, although these structures should be reviewed with qualified legal and tax professionals to determine whether they align with each household’s broader plan.” ~ Patrick Ray, a representative of The Retirement Group, a division of Wealth Enhancement.

In this article, we will discuss:

How intentionally defective grantor trusts (IDGTs) work.
The advantages and potential limitations of using an IDGT.
Key considerations for 3M employees evaluating this type of planning strategy.

An irrevocable trust arrangement known as an intentionally defective grantor trust (IDGT) allows the grantor to move assets out of their taxable estate while still being treated as the owner of those assets for income tax purposes. Many people, including 3M employees with high-growth or income-producing holdings, may benefit from using this strategy to support long-term wealth preservation.

How an Intentionally Defective Grantor Trust Works

For tax purposes, different kinds of trusts receive different treatment, and understanding the distinctions can help 3M professionals review planning strategies more effectively.

Revocable Trusts

In a revocable trust, the grantor is taxed on trust income and is regarded as the owner for income tax purposes. A separate trust income tax return is usually unnecessary. These assets generally remain inside the grantor’s taxable estate because the grantor maintains full control.

Irrevocable Trusts

An irrevocable trust is treated as its own tax entity, filing its own return and taking its own deductions. When properly drafted so the grantor does not retain certain powers or interests, assets transferred to an irrevocable trust are generally removed from the taxable estate, a detail that can matter for 3M professionals with substantial savings or investment holdings.

How IDGTs Combine These Features

An IDGT is structured as an irrevocable trust for estate and gift tax purposes, removing assets from the taxable estate, but is treated as a grantor trust for income tax purposes. As long as the grantor pays income taxes on trust earnings, the trust’s assets can grow outside the estate, which may appeal to 3M professionals with long-term legacy goals.

Why It’s Called “Intentionally Defective”

The trust is drafted so that, under IRS grantor-trust rules, the grantor remains the owner for income tax purposes due to certain retained powers. At the same time, the trust is irrevocable for estate tax purposes, allowing the assets to remain outside the taxable estate—a structure that may assist with multigenerational planning.

Advantages of an Intentionally Defective Grantor Trust

Because an IDGT is a grantor trust for income tax purposes, the grantor pays income tax on trust earnings. This leads to two important benefits that may interest 3M employees with high-value assets:

- Trust assets can grow for beneficiaries without being reduced by income tax payments.
- Income tax paid by the grantor reduces the taxable estate without being classified as a gift.

- This dynamic—where grantors use personal funds to pay taxes that would otherwise reduce trust assets—is often referred to as a “tax burn.”

How Assets Are Transferred to an IDGT

3M employees reviewing wealth transfer strategies may encounter two common approaches:

1. Gift or Partial Gift/Sale

A grantor can move assets to an IDGT as a gift. If the gift stays within the lifetime gift and estate tax exemption, it typically does not create out-of-pocket gift tax. Some planning approaches combine a partial gift with a sale to balance estate goals.

2. Sale to the IDGT

Many grantors sell assets to an IDGT in exchange for a promissory note with an interest rate at or above the IRS Applicable Federal Rate (AFR).

- The sale is typically not treated as a taxable gift if conducted at fair market value.
- Appreciation above the AFR occurs outside the grantor’s estate for beneficiaries.
- When AFR rules and loan requirements are followed, the note is treated as valid consideration and carries an interest obligation.

Potential Drawbacks of an IDGT

Once established, an IDGT is difficult to modify, similar to other irrevocable trusts. Outcomes also depend on the trust assets growing at a rate higher than the AFR. If that does not occur, the intended estate planning benefits may fall short—an important consideration for 3M employees reviewing various asset types.

Who Might Consider an IDGT?

An IDGT can be appealing for families facing potential estate tax exposure, especially when transferring assets with strong growth potential. This approach works best when the grantor has sufficient liquidity to continue paying the trust’s income taxes personally, a factor some 3M employees review when assessing retirement and estate liquidity. Because the structure requires precise legal drafting, it should be established with qualified legal counsel.

Need Support with IDGTs or Retirement Planning?

The Retirement Group can assist you in reviewing whether an IDGT fits into your broader retirement and estate plan as a 3M employee. For guidance tailored to your long-term goals, call us at (800) 900-5867 .

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Sources:

1. BMO Wealth Management. Herman, Brad. Intentionally Defective Grantor Trust. BMO Financial Group, Oct. 2021,
https://uswealth.bmo.com/media/filer_public/8b/3f/8b3f85c6-21b0-407e-bfbf-0f9b181c1673/bwm_idgtarticle_1103.pdf .

2. Fidelity Wealth Management. “What Is an Intentionally Defective Grantor Trust (IDGT)?” Fidelity Viewpoints , 4 Dec. 2025,
https://www.fidelity.com/viewpoints/wealth-management/insights/intentionally-defective-grantor-trusts .

3. Hirtle, Callaghan & Co. Estate Planning With Intentionally Defective Grantor Trusts.
Hirtle, Callaghan & Co., 2020,
https://www.hirtlecallaghan.com/wp-content/uploads/2020/08/Intentionally-Defective-Grantor-Trusts.pdf .

4. Nevada Trust Company. Ford-Grella, Jaclyn. “How Intentionally Defective Grantor Trusts Can Safeguard Assets for Future Generations.” Nevada Trust Company , 10 Dec. 2024,
https://www.nevadatrust.com/how-intentionally-defective-grantor-trusts-can-safeguard-assets-for-future-generations/ .

Given the recent decision by 3M to freeze its pension plans for non-union employees effective December 31, 2028, how should employees prepare for this significant change? What resources and strategies can they explore to ensure they are financially secure during retirement, considering the shift from traditional pension benefits at 3M to 401(k) plans?

Preparation for Pension Freeze at 3M: As 3M plans to freeze its pension plans for non-union employees by the end of 2028, employees should begin by assessing their current pension benefits and understanding how much they will have accrued by the freeze date. It's advisable for employees to consult financial advisors to discuss alternative retirement savings strategies, such as IRAs or other investment vehicles. Additionally, employees should take advantage of the company's matching contributions to 401(k) plans and consider increasing their contributions to maximize their retirement savings.

With 3M transitioning from a pension-based retirement system to a 401(k) structure, what implications does this have for employee contributions and investment options? How can 3M employees utilize the flexibility offered by 401(k) plans to align with their individual retirement goals, and what specific considerations should they keep in mind when selecting investments?

Implications for Employee Contributions at 3M: With 3M transitioning to a 401(k) model, employees will have more control over their retirement investments. This shift means that employees need to be more proactive in selecting investment options that align with their retirement goals. Employees should consider factors like risk tolerance, time horizon, and financial goals when selecting investments. Utilizing tools and resources offered by 3M, such as financial planning services and investment education workshops, can help employees make informed decisions.

How will the freeze on accrual of pension benefits affect the retirement planning process for employees who have been with 3M for many years compared to newer employees? What unique challenges might long-term employees face as they transition from relying on defined benefits to managing their retirement accounts through 3M?

Impact on Long-term vs. New Employees: Long-term 3M employees who have accrued significant pension benefits might find the transition challenging as they shift from a defined benefit to a defined contribution plan. These employees should review their projected pension payouts and consider additional savings or investment strategies to cover any shortfalls. Newer employees might be less affected as they have less accrued in the pension plan and potentially more time to adjust their savings strategies in the 401(k) plan.

What educational resources are available through 3M to assist employees in understanding their retirement plan options following the pension freeze? How can employees leverage these resources to make informed decisions about their future and ensure that they understand the differences between the pension plan and their new 401(k) options?

Educational Resources at 3M: 3M is likely to offer a range of educational resources to help employees understand their new retirement plan options. Employees should look out for seminars, webinars, and one-on-one counseling opportunities that can provide guidance on navigating the changes. The HR department at 3M will also be a valuable resource for accessing personalized advice and detailed explanations of the differences between the old pension plans and the new 401(k) options.

In light of the recent changes to 3M's pension structure, what steps can employees take to maximize their retirement savings over the next five years before the freeze takes effect? What savings strategies are recommended for 3M employees to ensure that they are adequately prepared for retirement given this significant policy change?

How does the decision by 3M to move to a 401(k) retirement model reflect broader trends in the corporate world regarding pension plans? What are the potential benefits and drawbacks of this shift from both the companyâ€™s and the employeesâ€™ perspectives, and how can employees navigate this changing landscape?

Broader Trends in Pension Plans: 3M's decision reflects a broader trend in the corporate world where companies are shifting from defined benefit pension plans to defined contribution plans like 401(k)s. This shift allows companies to reduce the volatility of pension liabilities on their balance sheets and provides employees with potentially higher returns on their retirement savings, albeit with higher risks. Employees need to become more financially literate to navigate this landscape effectively.

What mechanisms does 3M have in place to provide ongoing communication and support regarding the changes to the pension plan? How can employees at 3M stay informed about updates and optimally utilize company meetings or counseling sessions to address their retirement concerns?

Ongoing Communication and Support at 3M: 3M is expected to provide ongoing communication and support to employees regarding the pension changes. Regular updates, FAQs, and dedicated channels for raising concerns, such as HR hotlines or dedicated email addresses, will be crucial. Attending scheduled meetings and participating in counseling sessions can help employees stay informed and prepare adequately for the future.

As the pension plans at 3M are frozen, what options do employees have if they are uncertain about their retirement strategy? How can 3M's HR department assist employees in evaluating their current financial situations and developing customized retirement plans?

Options for Uncertain Employees: For employees uncertain about their retirement strategy post-pension freeze, 3M's HR department can provide significant assistance. HR can offer tools for financial modeling and planning, assist in setting up meetings with financial planners, and provide detailed comparisons of various retirement strategies. Employees should actively seek out these resources and engage with HR to build a personalized retirement plan.

How will the freeze of pension plans impact the overall financial stability of 3M retirees, and what considerations should current employees keep in mind as they anticipate retirement? How does this shift align with 3Mâ€™s commitment to employee welfare and long-term planning for their staff?

Impact on Financial Stability of Retirees: The freeze of the pension plans at 3M could impact the financial stability of retirees, especially those close to retirement who have less time to adjust their savings strategies. Employees should review their anticipated income from the pension plan and assess any potential shortfalls. Diversifying investments and seeking ways to generate additional income during retirement can help mitigate the impact of the pension freeze.

If employees at 3M wish to engage with the company's Human Resources department to gain clarity on the new pension and retirement policy implementations, what is the most effective way to reach out? How can 3M staff gain access to additional support and resources related to their retirement options?

Engaging with HR for Clarity: Employees seeking clarity on the new pension and retirement policies at 3M should reach out to the HR department effectively. Utilizing company-provided channels such as HR portals, direct emails, or scheduled office hours can facilitate better understanding and access to resources. Engaging in open dialogues during HR-led sessions or through direct consultations can help employees gain the necessary support and guidance.

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.

Transition to 401(k) plan, pension freeze by 2028, annuity transfer in 2024 covering $2.5B obligations for 23,000 retirees.

3M offers RSUs to its executives and eligible employees as part of its long-term incentive plan. RSUs vest over time and are intended to align employees' interests with shareholders.