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

“Medtronic PLC 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.

“Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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

Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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 Medtronic PLC 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 are the eligibility requirements for the Medtronic Retirement Plan, and how do they apply to employees who were hired before and after the cut-off date of January 1, 2016? Employees need to understand these nuances, as they affect the types of retirement benefits they may be entitled to under the Medtronic Retirement Plan.

Eligibility Requirements: Employees hired before January 1, 2016, may be eligible for either the Final Average Pay Pension or the Personal Pension Account benefit, depending on their hire date. Employees hired or rehired after January 1, 2016, are not eligible for the Medtronic Retirement Plan(Medtronic_2016_June_Ret…).

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Vesting Process: The Final Average Pay Pension benefit becomes nonforfeitable after five years of service or reaching age 62, while the Personal Pension Account becomes vested after three years of service(Medtronic_2016_June_Ret…).

Can Medtronic employees expect any differences in the way their pension benefits are calculated if they decide to retire early versus waiting until normal retirement age? It's crucial for employees to know how early retirement might impact their payouts from the Medtronic Retirement Plan.

Early vs. Normal Retirement Calculation: Early retirement benefits under the Final Average Pay Pension will be reduced based on the age at retirement. For example, at age 55, employees receive 50% of the normal benefit(Medtronic_2016_June_Ret…).

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Maximizing Personal Pension Account: Medtronic credits 5% of eligible compensation annually to the Personal Pension Account, which also accrues interest based on the 10-year U.S. Treasury rates(Medtronic_2016_June_Ret…).

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Benefit Payment Options: Employees can choose between receiving their pension as a single life annuity, joint and survivor annuity, or a lump sum payment depending on their circumstances(Medtronic_2016_June_Ret…).

What protections does the Medtronic Retirement Plan offer regarding spousal benefits and qualified domestic relations orders (QDROs)? This understanding is particularly important for employees who may go through life changes, such as marriage or divorce.

Spousal Benefits and QDROs: The plan provides protections for spousal benefits, including joint and survivor annuities. QDROs may mandate the division of pension benefits in the case of divorce(Medtronic_2016_June_Ret…)(Medtronic_2016_June_Ret…).

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Forms and Deadlines for Retirement Benefits: Employees must contact the Retirement Service Center and submit required forms within 180 days of retirement to start receiving their benefits(Medtronic_2016_June_Ret…).

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Handling Benefit Denials: Employees can appeal a benefit denial by submitting a written claim to the Plan Administrator within one year of discovering the issue. A formal appeals process is in place(Medtronic_2016_June_Ret…).

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