New Update: Healthcare Costs Increasing by Over 60% in Some States. Will you be impacted?

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

Healthcare Provider Update: First Horizon offers health, dental, and vision insurance tailored to individual and family needs. Employees benefit from HSAs, FSAs, disability coverage, and parental leave. The company provides a 401(k) with up to 6% matching, adoption reimbursement, and wellness programs. Additional perks include tuition reimbursement, mentoring, and digital wellness platforms3. First Horizon With ACA premiums projected to rise sharply, First Horizons employer-sponsored plans and financial wellness tools help employees avoid the volatility of marketplace costs. Their matched savings and flexible spending options provide a buffer against rising healthcare expenses. Click here to learn more

“First Horizon 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.

“First Horizon 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 First Horizon 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 First Horizon 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 First Horizon 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 First Horizon 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 First Horizon 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 First Horizon 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

First Horizon 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 First Horizon 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 First Horizon 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 First Horizon employee. For guidance tailored to your long-term goals, call us at (800) 900-5867 .

Featured Video

Articles you may find interesting:

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 type of retirement savings plan does First Horizon offer to its employees?

First Horizon offers a 401(k) retirement savings plan to help employees save for their future.

Does First Horizon provide matching contributions to the 401(k) plan?

Yes, First Horizon provides a matching contribution to the 401(k) plan, which helps employees maximize their retirement savings.

What is the eligibility requirement to participate in First Horizon's 401(k) plan?

Employees at First Horizon are eligible to participate in the 401(k) plan after completing a specific period of service, typically within the first year of employment.

How can employees at First Horizon enroll in the 401(k) plan?

Employees can enroll in First Horizon's 401(k) plan through the company’s HR portal or by contacting the HR department for assistance.

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

First Horizon offers a variety of investment options in its 401(k) plan, including mutual funds, target-date funds, and other investment vehicles.

Can employees at First Horizon take loans against their 401(k) balance?

Yes, First Horizon allows employees to take loans against their 401(k) balance under certain conditions, as outlined in the plan documents.

What is the vesting schedule for First Horizon's 401(k) matching contributions?

The vesting schedule for First Horizon's matching contributions typically follows a graded schedule, which means employees earn ownership of the match over a period of time.

Are there any fees associated with First Horizon's 401(k) plan?

Yes, there may be administrative fees associated with First Horizon's 401(k) plan, which are disclosed in the plan documents.

How often can employees at First Horizon change their 401(k) contribution amount?

Employees at First Horizon can change their 401(k) contribution amount at any time, subject to the plan's guidelines.

What is the maximum contribution limit for First Horizon's 401(k) plan?

The maximum contribution limit for First Horizon's 401(k) plan is set by the IRS and may change annually; employees should refer to the latest IRS guidelines for specifics.

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

First Horizon National Corporation offers both a pension plan and a 401(k) plan to its employees. The First Horizon National Corporation Pension Plan is a defined benefit corporate pension fund that was established in 1946. This pension plan provides retirement, death, and disability benefits to eligible employees and their beneficiaries. The assets of the pension plan are managed by the Pension, Savings, and Flexible Compensation Committee, with First Tennessee Bank National Association serving as the trustee (PitchBook). In addition to the pension plan, First Horizon provides a 401(k) plan where employees can save for retirement with contributions matched by the company up to 6% of their pre-tax income. The 401(k) plan also includes various savings and money management tools, such as Health Savings Accounts (HSA) and Flexible Spending Accounts (FSA), which allow employees to set aside pre-tax income for healthcare and dependent care expenses

Restructuring and Layoffs: In early 2024, First Horizon announced a significant restructuring plan aimed at streamlining operations and reducing costs. The bank plans to cut approximately 5% of its workforce over the next year as part of this initiative. This move is in response to increasing operational expenses and the need to enhance efficiency in a challenging economic environment. This news is particularly relevant as it reflects broader trends in the banking sector where institutions are adjusting their workforces to remain competitive amidst economic uncertainty.

First Horizon Corporation (FHN) provides a comprehensive employee stock option and Restricted Stock Unit (RSU) program aimed at retaining top talent and incentivizing long-term performance. First Horizon offers both stock options and RSUs to eligible employees, primarily those in executive or senior management roles. These awards generally vest over a period of three to five years, with specific performance metrics tied to company performance and stock price. Employees who meet certain job levels and performance criteria are eligible to participate in these equity compensation plans. In 2022, First Horizon offered RSUs that vest annually, providing employees with ownership stakes in the company. By 2023 and 2024, the bank continued this program with slight adjustments, including expanded eligibility and adjusted performance criteria (

First Horizon Health Benefits Overview Company Website: The official First Horizon website provides the most direct and accurate information. Glassdoor: This site often has employee reviews and details about health benefits, including recent changes or feedback from employees. Indeed: Similar to Glassdoor, Indeed might have employee reviews and specific information about health benefits and any recent updates. LinkedIn: Sometimes companies post updates about employee benefits or changes in health-related policies here. Benefits.gov: This site provides general information about employee benefits and might have relevant details or changes affecting First Horizon.