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

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Healthcare Provider Update: Healthcare Provider for CSX: CSX Corporation has partnered with Aetna, a division of CVS Health, to provide healthcare benefits for its employees. This collaboration allows CSX employees access to a wide range of health services and insurance plans tailored to meet their specific needs. Potential Healthcare Cost Increases in 2026: In 2026, CSX and its employees may face significant healthcare cost challenges, as the landscape for health insurance is set to experience considerable changes. With proposed premium hikes in the Affordable Care Act marketplace reaching as much as 66% in some states, the potential expiration of enhanced federal premium subsidies may exacerbate out-of-pocket expenses for many enrollees. A forecast indicates that over 22 million individuals could see their premiums increase by more than 75%, driven by rising medical costs and insurers' aggressive rate adjustments. This surge in costs could create financial strain not only for individual employees but also for the company's overall healthcare budget, necessitating strategic planning and proactive measures for 2026. Click here to learn more

“CSX 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.

“CSX 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:

  1. How intentionally defective grantor trusts (IDGTs) work.

  2. The advantages and potential limitations of using an IDGT.

  3. Key considerations for CSX 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 CSX 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 CSX 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 CSX 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 CSX 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 CSX 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

CSX 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 CSX 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 CSX 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 CSX 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/ .

What is the purpose of the 401(k) plan at CSX?

The 401(k) plan at CSX is designed to help employees save for retirement by allowing them to contribute a portion of their salary on a pre-tax basis.

How can CSX employees enroll in the 401(k) plan?

CSX employees can enroll in the 401(k) plan through the company’s HR portal or by contacting the HR department for assistance.

Does CSX offer a company match for 401(k) contributions?

Yes, CSX offers a company match for 401(k) contributions, which allows employees to increase their retirement savings.

What is the maximum contribution limit for CSX employees under the 401(k) plan?

The maximum contribution limit for CSX employees under the 401(k) plan is determined by the IRS and may change annually. Employees should check the latest IRS guidelines for the current limit.

Can CSX employees take loans against their 401(k) savings?

Yes, CSX allows employees to take loans against their 401(k) savings, subject to certain conditions and limits outlined in the plan documents.

What investment options are available in CSX's 401(k) plan?

CSX's 401(k) plan offers a variety of investment options, including mutual funds, stocks, and bonds, allowing employees to choose based on their risk tolerance and retirement goals.

When can CSX employees start withdrawing from their 401(k) plan?

CSX employees can start withdrawing from their 401(k) plan at age 59½, or earlier under certain circumstances, such as financial hardship.

Is there a vesting schedule for CSX's 401(k) company match?

Yes, CSX has a vesting schedule for the company match, which means employees must work for a certain period to fully own the matched contributions.

How often can CSX employees change their 401(k) contribution amount?

CSX employees can change their 401(k) contribution amount at any time, subject to the plan's guidelines and payroll processing schedules.

What happens to a CSX employee's 401(k) if they leave the company?

If a CSX employee leaves the company, they can choose to roll over their 401(k) balance to another retirement account, cash out, or leave the funds in the CSX plan if permitted.

With the current political climate we are in it is important to keep up with current news and remain knowledgeable about your benefits.
The pension plan for CSX employees is part of the Railroad Retirement Act, specifically referred to as the CSX Railroad Retirement plan. Eligibility and Qualifications: Years of Service: Employees typically need to have at least 10 years of service to be eligible for the pension plan benefits. Age Qualification: Full retirement benefits are available at age 60 with 30 years of service or age 62 with fewer years of service. Pension Formula: The pension is calculated based on the highest three earning years. The formula generally provides 80% of the average highest earnings after 30 years of service. Specific Terms and Acronyms: RRB (Railroad Retirement Board): Governs the administration of the railroad retirement benefits. Tier I and Tier II Benefits: Components of the Railroad Retirement benefits, with Tier I similar to Social Security and Tier II providing additional benefits based on railroad earnings. CSX 401(k) Plan: Name of 401(k) Plan: CSX offers the CSXtra 401(k) plan. Eligibility and Qualifications: Who Qualifies: All full-time employees are eligible to participate in the CSXtra 401(k) plan. Contribution Limits: Employees can contribute from 1% to 50% of their eligible pay up to the IRS limits, with additional catch-up contributions for those aged 50 and older. Company Match: CSX matches 100% of the first 1% of the employee's contribution and 50% of the next 5% of the contributions.
Layoffs and Restructuring: CSX has not announced significant layoffs recently but is continuously adjusting its workforce through normal attrition and targeted hiring to meet changing market demands.
2022: In 2022, CSX granted stock options and RSUs to key executives, focusing on aligning their incentives with the company's strategic goals. The grants were part of the annual executive compensation review. 2023: The 2023 program continued to emphasize performance-based RSUs, rewarding employees for meeting specific operational and financial targets. This year's grants included a significant component tied to sustainability and ESG (Environmental, Social, Governance) metrics, reflecting the company's commitment to sustainable growth. 2024: In 2024, CSX expanded its RSU program to include more mid-level management positions, recognizing the broader impact of these roles on company performance. This year’s stock options included features to enhance retention and reward long-term loyalty among employees.
Health Insurance: CSX offers various health insurance plans, including options with low co-pays and comprehensive coverage through Aetna. These plans cover a wide range of medical services and prescriptions. Wellness Programs: To promote physical and mental health, CSX has implemented wellness programs that include health assessments, fitness challenges, and access to wellness resources. Flexible Spending Accounts (FSAs): Employees can set aside pre-tax dollars for healthcare expenses through Health Care FSAs. The contribution limit for 2024 is $3,050, with a carryover limit of $610 from the previous year. Accidental Death and Dismemberment (AD&D) Insurance: CSX provides AD&D insurance, which covers employees in case of serious injuries or death due to accidents, with various coverage options based on annual pay. Recent Employee Healthcare News: In recent years, CSX has maintained stable health insurance premiums while enhancing the benefits package to meet evolving needs. The company continues to focus on offering competitive and comprehensive health benefits to attract and retain top talent. For instance, CSX has been recognized for its support of military and first responders through its Pride in Service program, which also contributes to the overall health and wellness of its employees.
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For more information you can reach the plan administrator for CSX at 500 Water St Jacksonville, FL 32202; or by calling them at (904) 359-3200.

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