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

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“FMC 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.

“FMC 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 FMC 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 FMC 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 FMC 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 FMC 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 FMC 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 FMC 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

FMC 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 FMC 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 FMC 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 FMC 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/ .

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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