⚠ Critical Distinction · For CPAs & Sophisticated Sellers

A Structured Installment Sale is NOT a Deferred Sales Trust.

If your CPA hears "installment sale tax planning" and worries it's the audit-magnet structure they've read about in IRS warnings — they're thinking of DSTs and Monetized Installment Sales. Those are different products with different legal foundations. The SIS uses the same IRC §453 the IRS has codified for 100+ years.Here's exactly how they differ.

Critical distinction — read this

SIS is NOT a traditional seller-financed installment sale.

When most people hear “installment sale,” they think of the old-school version where the buyer pays the seller directly over time — like seller-financed real estate. That arrangement carries massive buyer-default risk for the seller and is NOT what the SIS does.

QuestionTraditional installment saleStructured Installment Sale (SIS)
Who owes the seller the payments?The BUYERAn A-rated INSURANCE CARRIER (via third-party assignment company)
When does the buyer pay?Monthly to seller for 10-30 yearsFull cash at closing (just like any normal sale)
If buyer defaults?Seller stops getting paid — buyer-default riskN/A — buyer already paid in full. Carrier owes the seller, not the buyer.
Backing the payment stream?Buyer’s creditworthiness onlyA-rated insurance carrier’s general account + CLHIGA state guaranty (80%/$250K cap)
Tax treatment§453 installment method§453 installment method (same code, same blessing in Rev. Proc. 2005-26)

Bottom line: the SIS keeps the §453 spread-tax benefit of the old installment sale but eliminates the buyer-default risk. The buyer wires the full sale price to escrow on closing day — same as any cash sale. Escrow splits the wire per the SIS rider: any cash carve-out goes to you, the rest goes to the assignment company which immediately purchases an annuity from an A-rated carrier. The carrier becomes the obligor.

The 30-second version

Several different "installment-sale-style" tax structures get pitched to high-net-worth sellers. They look similar from the outside, but they have completely different legal foundations. Some are bulletproof. Some are listed-transaction audit magnets.

✓ Structured Installment Sale (SIS) — IRC §453The buyer pays the seller through a third-party assignment company (typically an A-rated annuity carrier). It's the same §453 installment-sale method everyone has used for 100+ years. The seller doesn't control the funds, doesn't have constructive receipt, doesn't use a trust. No IRS challenge — established tax law.
✗ Deferred Sales Trust (DST) — No IRC code sectionA trust holds the property, "sells" it, and pays the seller in installments. Marketed as eliminating gain via §453 mechanics, but the IRS has challenged the structure repeatedly. Multiple practitioners have faced enforcement. No statutory backing. Audit-magnet.
✗ Monetized Installment Sale (MIS) — IRS LISTED TRANSACTIONThe seller takes a non-recourse loan against the installment note, effectively monetizing the deferral while still claiming §453 treatment. The IRS officially listed MIS as a "listed transaction" in 2024 — meaning every taxpayer using it must disclose, and the IRS will likely audit. Stop, do not pass go.
✓ Charitable Remainder Trust (CRT) — IRC §664A different structure entirely — uses the charitable trust code, not the installment method. Established 1969, used by Fortune 500 founders and operating philanthropies for decades. No challenge.Different fit than SIS (requires charitable intent), but equally bulletproof.
The full comparison

Side-by-side: SIS vs DST vs Monetized Installment vs CRT

Structure Tax Code IRS Position Funded By Seller Control
Structured Installment Sale (SIS)This calculator IRC §453 ✓ Codified
Same law as standard installment sales — settled for 100+ years
A-rated annuity carrier (assignment company) No constructive receipt
Deferred Sales Trust (DST)No code section None (relies on §453 by analogy) ✗ Challenged
Multiple Tax Court losses for promoters; IRS asserts constructive receipt
Trust holds property + sells Trust controls funds
Monetized Installment Sale (MIS)IRS Notice 2023-34 Strained §453 + §752 ✗ LISTED TRANSACTION (2024)
Mandatory disclosure required; promoter penalties; near-certain audit
Loan-backed installment note Effective receipt via loan
Charitable Remainder Trust (CRT)IRC §664 IRC §664 ✓ Codified
Same law Stanford / Harvard / hospitals have used for 60+ years
Irrevocable trust holds + manages No reclaim — remainder to charity
1031 Like-Kind ExchangeIRC §1031 IRC §1031 ✓ Codified
Real estate only since 2017 TCJA; common practice
Qualified intermediary holds proceeds Limited (must reinvest 180d)
Delaware Statutory Trust (1031)IRC §1031 fractional IRC §1031 ✓ Codified
Not to be confused with Deferred Sales Trust — completely different product
DST sponsor holds fractional interest Locked 5-10 years
In detail

Why the SIS is structurally different from a DST

✓ THE GOOD ONE — SIS
USES CODIFIED §453

Structured Installment Sale (SIS)

The buyer at closing assigns the obligation to pay the seller's installments to a third-party assignment company — almost always a name-brand A-rated insurance carrier. The carrier funds the obligation immediately with a lump sum from escrow, then pays the seller per the schedule.

Critically: the seller doesn't hold the funds. The seller doesn't have constructive receipt. The seller has no economic relationship to the buyer after closing. The buyer is fully discharged. This is straight IRC §453 installment-sale treatment — the same code section any farmer selling on installment to a neighbor has used for a century.

Why CPAs don't object: there's nothing to object to. It's how installment sales have worked since 1926. The only "innovation" is that the assignment company is an A-rated annuity carrier rather than the buyer themselves — which actually strengthens seller protection because the carrier's balance sheet is far stronger than any private buyer's.

Legal foundation:IRC §453, Treas. Reg. §15A.453-1, Rev. Proc. 2005-26. Used continuously since 1983 specifically for personal injury / wrongful death settlements (§104(a)(2) tax-free) and since the mid-1990s for taxable structured installment sales of business interests and real estate. No IRS challenge to the fundamental structure — the only audits arise around §453 mechanics (gain recognition, recapture, §453A interest charge), not the structure itself.
✗ THE PROBLEMATIC ONE — DST
IRS HAS CHALLENGED

Deferred Sales Trust (DST)

A promoter sets up an irrevocable trust. The seller "sells" the property to the trust in exchange for an installment note. The trust then sells the property to the actual buyer and pays the seller per the note schedule. The seller claims §453 installment treatment based on the seller-to-trust sale.

The problem: the IRS argues the seller has effective control over a trust they set up for their own benefit, and that the "sale" to the trust isn't a real arm's-length transaction. Multiple Tax Court cases have ruled against DST promoters. The trust's assets, the trustee's role, the seller's beneficial interest — every piece of the structure invites scrutiny.

Specific issues: trustee is often picked by the promoter, not independent. Trust assets are sometimes invested in vehicles benefiting the promoter. Trust mechanics often blur the line between "trust holds funds" and "seller controls funds." There's no statutory authority for the structure — it's a clever theory, not codified law.

The history:IRS Office of Chief Counsel issued guidance unfavorable to DST structures as far back as 2008 (CCA 200846040). Multiple promoters have been enjoined or penalized. Estate of Krzemien v. Comm'r and similar matters have produced bad outcomes for DST users. The structure is sold by motivated promoters who collect 6-12% in fees, often with limited disclosure of audit risk to the seller.
✗ THE LISTED-TRANSACTION ONE — MIS
IRS LISTED TRANSACTION 2024

Monetized Installment Sale (MIS)

The seller does a §453 installment sale (often through a promoter-run vehicle), then immediately takes out a non-recourse loan against the installment note for ~95% of the sale value. Functionally, the seller has the cash today but claims §453 deferral on the gain. The IRS calls this what it is: monetization of the deferral.

In 2024, the IRS formally designated Monetized Installment Sales as a "listed transaction" under Treas. Reg. §1.6011-4. This means: every taxpayer using one must file Form 8886 disclosing the transaction, every advisor recommending one must file Form 8918 as a material advisor, and the IRS has put the structure on its specific enforcement targeting list.

If you've been pitched a "monetized installment sale" or any §453 structure where you get a loan against the note, stop and consult a tax attorney before signing. Listed transactions carry steep penalties for non-disclosure ($10K minimum, often higher), and the underlying tax position usually loses on audit.

Citations:IRS Notice 2023-34 (initial warning), Final Listed Transaction designation in 2024 per Final Regulation 9089 / TD 10003. Romanowski v. Commissioner (Tax Court 2023) — taxpayer using MIS lost $1.3M tax + penalties + interest. The IRS's Large Business & International division has audit teams specifically dedicated to these structures.
✓ THE OTHER GOOD ONE — CRT
USES CODIFIED §664

Charitable Remainder Trust (CRT)

A completely different structure — uses charitable trust law, not installment-sale mechanics. The seller donates the appreciated property into an irrevocable trust. The trust sells the property tax-free (because it's a charitable trust). The trust pays the seller (or other beneficiaries) an income stream for life or a term of years. Whatever's left at the end goes to charity.

Why this is safe:CRTs were codified in 1969 under IRC §664. Stanford University, Harvard, the Mayo Clinic, every operating charity in America has accepted CRT-funded gifts for decades. The IRS has clear regulations governing CRUTs (unitrusts) and CRATs (annuity trusts). There's no ambiguity about whether they work — they do.

The tradeoff: the remainder goes to charity. If you don't want to make a charitable gift, the CRT isn't your tool. But for sellers with even modest charitable intent (or those willing to use a wealth-replacement life insurance policy to restore the family wealth via the death benefit), the CRT often beats every other structure on after-tax math.

Legal foundation:IRC §664; Treas. Reg. §1.664-1 through §1.664-4; IRS Publication 1457 (actuarial factors); annual Rev. Procs. updating the §7520 rate used for deduction calculations. The CRT remainder beneficiary must receive at least 10% of the initial fair market value (the "10% remainder test"). Trust must be irrevocable. Distributions taxed under the WIFO (worst-in-first-out) tier system.
Common confusion

"Wait, isn't a DST a real-estate thing?"

Yes — but there are TWO different "DSTs" and they're completely different products.This is one of the biggest sources of confusion in this space.

"DST" #1: Delaware Statutory Trust (1031 vehicle) — LEGITIMATE

A real-estate investment vehicle where multiple investors hold fractional interests in a pool of properties. Used as a 1031 exchange replacement property for sellers who want passive real estate exposure. Codified under IRC §1031 and Rev. Rul. 2004-86. Legitimate, widely used, no IRS challenge to the structure (only to specific bad sponsors). 3-5% upfront sponsor fees are the main downside, plus illiquidity.

"DST" #2: Deferred Sales Trust — IRS-CHALLENGED

A trademark-protected promotional structure marketed as a §453 deferral vehicle. No connection to Delaware Statutory Trusts whatsoever — the name overlap is deeply unfortunate and intentionally misleading. Multiple Tax Court losses. Office of Chief Counsel guidance against it. If you've been pitched a "Deferred Sales Trust" to defer your sale gain, that's the one to avoid.

Practical test: if the structure your CPA or an advisor is describing involves fractional real-estate ownership, they mean the legitimate Delaware Statutory Trust. If it involves a trust holding the proceeds of your sale and paying you in installments, that's the audit-magnet Deferred Sales Trust. Different products. Different outcomes.

Common confusions

Other structures attorneys & CPAs may mix this up with

Beyond the DST and the MIS, the §453 SIS gets confused with at least a dozen other tax-planning structures. Here’s a quick disambiguation table so advisors can rule each one in or out.

StructureCode sectionHow it differs from SIS
Deferred Sales Trust (DST)
IRS-challenged
None — promoter-definedNo specific IRC section. Sale to a trust that holds the proceeds. IRS has issued summonses on these for over a decade.
Monetized Installment Sale (MIS)
Listed transaction since 2023
§453 + non-recourse loanIRS Notice 2023-24 made these a "listed transaction" — reportable, penalty-exposed. Uses a non-recourse loan against the installment note.
Private Annuity Trust (PAT)
Killed by IRS in 2006
Pre-2006 §72 / §453Proposed regs in Oct 2006 effectively shut down PATs by requiring upfront gain recognition. Different mechanic, same intent — commonly confused with SIS but no longer viable.
Self-Cancelling Installment Note (SCIN)§453 + §2031Installment note that cancels at the seller’s death (estate-planning device). Requires actuarially-adjusted premium. Different beast from a carrier-funded SIS — SCINs use family/buyer notes, not insurance carriers.
Installment Sale to IDGT / IDIT§453 + grantor trust rulesSale of appreciated asset to an Intentionally Defective Grantor Trust the seller created. Used for estate freezing. Note still backed by trust/grantor — not by an A-rated carrier.
Delaware Statutory Trust (1031 DST)
Legitimate but different
§1031 fractionalThe "good DST" — passive fractional real estate ownership that qualifies for 1031 deferral. Confused with "Deferred Sales Trust" because the acronym is identical. Has nothing to do with §453.
1031 Like-Kind Exchange
Legitimate but different
§1031Tax DEFERRAL by reinvesting into like-kind real estate within 180 days. SIS instead SPREADS recognition under §453 without requiring reinvestment in real estate. Full comparison.
Charitable Remainder Trust (CRT)
Legitimate
§664Tax ELIMINATION by donating the asset to a §664 charitable trust. SIS instead spreads tax under §453. Different code, different mechanics, different fit. CRT page.
Opportunity Zone Fund (QOF)§1400Z-2Capital-gain deferral by reinvesting into a Qualified Opportunity Fund within 180 days. Requires holding the QOF investment for 10 years for the full benefit. Independent of §453.
Straight seller-financed installment note§453Same §453 treatment as SIS, but the BUYER is the obligor — not a carrier. Seller bears full buyer-default risk. SIS adds the carrier-assignment infrastructure to shift that risk to an A-rated insurer.
Sale-leaseback & earnouts§§451, 1234A, 1239Different gain-timing mechanisms — not §453. Earnouts use "open transaction" treatment when contingent. Often discussed alongside SIS but governed by entirely different rules.
The literature — receipts

Where the IRS talks about §453 & the structured installment sale

Every citation below is publicly available on irs.gov, the U.S. Code, or the Cornell LII. If your CPA or attorney wants the source documents, hand them this list.

Core statute

  • IRC §453 — Installment Method.Codifies pro-rata gain recognition as installment payments are received. On the books since the Revenue Act of 1926; current §453 from the Installment Sales Revision Act of 1980. 26 U.S.C. §453 (Cornell LII)
  • IRC §453A — Interest charge on deferred tax liability.Applies a deemed-interest charge on installment-sale obligations >$5M outstanding at year-end. 26 U.S.C. §453A (Cornell LII)
  • IRC §453B — Gain or loss on disposition of an installment obligation.Governs what happens if the seller later sells, gives, or transfers the installment obligation. 26 U.S.C. §453B
  • IRC §130 — Qualified assignments (structured-settlement infrastructure).Provides the carrier-assignment framework that the structured-settlement industry built and that SIS placements use for taxable §453 sales. 26 U.S.C. §130

Treasury regulations

  • Treas. Reg. §15A.453-1 — Installment method reporting for sales of real property and casual sales of personal property.The full operating manual: how to compute gross profit ratio, contract price, and pro-rata gain each year. 26 CFR §15A.453-1
  • Treas. Reg. §1.453-12 — Allocation of unrecaptured section 1250 gain.How depreciation recapture interacts with installment-method recognition. 26 CFR §1.453-12

Revenue Procedures & Rulings

  • Rev. Proc. 2005-26 — Section 453 + assignment company.Direct IRS guidance confirming the carrier-assignment infrastructure used in modern SIS placements qualifies for §453 installment treatment on taxable sales. This is the single most important document for proving SIS legality. Rev. Proc. 2005-26 (PDF)
  • Rev. Rul. 79-220 — Timing of gain recognition on installment sale.Confirms that installment-method gain is recognized only as cash is constructively received.
  • Rev. Rul. 82-122 — Assignment of installment obligation to a third party.Addresses tax consequences when an installment obligation is transferred to a different obligor.
  • Rev. Rul. 73-451, 76-498 — Structured-settlement carrier-assignment background.Pre-§130 IRS rulings that established the carrier-assignment mechanic later codified for personal-injury and adapted for taxable §453 sales.

Official IRS publications & forms

  • IRS Publication 537 — "Installment Sales".The official taxpayer-facing IRS publication explaining §453 mechanics. Pub 537 (PDF)
  • IRS Form 6252 — "Installment Sale Income".The form the seller files each year payments are received under §453. Form 6252 (PDF)
  • IRS Pub 1457 — Actuarial tables.Used for the §7520 / charitable deduction calculations referenced in the CRT path.

What the IRS has flagged as NOT legitimate (the look-alikes)

  • IRS Notice 2023-24 — Monetized Installment Sales as listed transactions.Treasury and IRS formally identified MIS transactions as "listed transactions" requiring disclosure under §6011 with serious penalty exposure. Notice 2023-24 (PDF)
  • CCA 201310024 — Deferred Sales Trust ("DST") attack.Chief Counsel Advice memo undermining the "Deferred Sales Trust" structure under §453. The IRS Office of Chief Counsel has issued summonses on these for over a decade.
  • Proposed Treas. Reg. §1.72-6 (Oct 2006) — killed Private Annuity Trusts (PATs).Required upfront gain recognition, effectively ending the PAT structure that was a §72/§453 hybrid.
Bottom line: the SIS sits inside the well-defined, well-documented §453 + Rev. Proc. 2005-26 framework. The DST sits outside it. The MIS sits inside §453 but with a non-recourse loan that the IRS specifically flagged as a listed transaction. Different structures, different IRS positions, different risk profiles.
More structures the IRS has flagged

Other "shenanigan" tax-deferral schemes to know about

Beyond the DST and MIS, here are other promoter-marketed structures the IRS has actively challenged. If a salesperson pitches any of these as an alternative to a §453 SIS, walk away — and consider whether your CPA and attorney are appropriately licensed for the specific structure.

StructureIRS positionWhy it’s risky
831(b) Micro-Captive Insurance
Selling business and "insuring" it via a captive you own
Listed transaction since 2016 (Notice 2016-66, expanded 2023)Premiums paid to your captive are deducted; captive elects §831(b) to exclude up to $2.85M in premium income. IRS treats most as abusive when "insured" risks are not real arm’s-length insurance.
Syndicated Conservation Easement
Inflated valuation of donated easement
Listed transaction since 2017 (Notice 2017-10)Promoter buys land, divides into LP interests, claims a charitable deduction 4-10× the LP cost. IRS has won most challenged cases. Major audit + penalty exposure.
Self-Directed IRA + LLC + Real Estate flip
Selling personal property to your IRA-owned LLC
Prohibited transaction under §4975If structured to benefit the IRA owner personally (self-dealing), IRS disqualifies the IRA — full distribution treated as taxable, plus 10% penalty if under 59½.
Wraparound Annuity / Charitable Lead Trust gimmicksMultiple court losses for promotersLayering an annuity inside a trust to claim a charitable deduction + tax deferral. Courts have collapsed these when the “charity” is illusory.
1031 Exchange with non-Qualified Intermediary
Using a friend / lawyer / yourself as QI
§1031 disqualified — full gain Year 1§1031 requires a Qualified Intermediary that meets specific independence + bonding requirements. DIY arrangements void the exchange.
“Charitable Remainder Sham Trust”
CRT without proper Pub 1457 actuarial deduction
CRT disqualified retroactively under §664Trust drafted by a non-CRT-experienced attorney that fails the §664 actuarial requirements (5% probability test, >10% remainder factor). IRS reclassifies the whole structure as a personal sale.
Roth Conversion via Sham LoanSubstance-over-form attackBorrowing to fund a Roth conversion with a non-arm’s-length loan from a related party. Courts disregard the loan and assess the conversion tax + penalties.
“International Tax-Free Trust” (offshore)FATCA reportable + §679 grantor rulesOffshore promoters pitch “tax-free” trusts in Cook Islands, Belize, etc. Reality: §679 treats the U.S. person as grantor (taxable on all trust income); FATCA + FinCEN penalties for non-disclosure are crushing.
⚠ The market-performance risk

When a “trust” ties your payments to market performance — be careful

The most common “Deferred Sales Trust” pitch goes like this: “Your sale proceeds go into a trust, the trustee invests them in a diversified portfolio, and you get paid monthly from the investment returns.”

That sounds reasonable — until you read the fine print. The trust’s ability to pay you depends entirely on how its investments perform. If the trustee invests in equities and the market drops 40% in a year (like 2008 or 2022), the trust doesn’t have the assets to pay you anymore. Your “guaranteed installment” isn’t guaranteed by anyone.

Three questions to ask any trust-based structure

  1. Who guarantees the payment stream? If the answer is “the trust’s investment performance,” the payment stream is not actually guaranteed. The trust is just a wrapper around market exposure.
  2. What happens if the trust’s investments underperform? If the trust can reduce, delay, or default on your payments — you bear market risk, not the trust.
  3. Is there a third-party A-rated obligor backstopping the payments? In a properly structured SIS, an A-rated insurance carrier becomes the obligor — the carrier’s reserves and state guaranty fund (CLHIGA for CA) back the contract. There is no comparable backstop in a market-tied trust.
How the SIS solves this

The §453 Structured Installment Sale uses an A-rated insurance carrier’s annuity contract as the payment obligation. The carrier’s general account — not a discretionary investment portfolio — backs every payment. State insurance guaranty associations (CA = CLHIGA, 80% of present value with $250K cap per insured) provide additional protection if the carrier fails. Market performance does not affect your monthly check.

⚠ Properly funded vs improperly funded

A properly funded SIS = sale proceeds wired at closing directly to a third-party assignment company that immediately purchases an A-rated carrier annuity. An improperly funded structure = proceeds held by a trust/escrow with the seller as beneficiary, then later “invested” in an annuity or portfolio. The IRS can challenge the latter as constructive receipt — collapsing the §453 deferral and taxing the seller on the full gain in Year 1.

What this means for you

If you're considering a §453 structure for your sale

Three questions to ask any advisor pitching you "installment sale tax planning":

1. "Is this structured through an A-rated insurance carrier as the assignment company?"

If yes → SIS. Safe. If "no, we use a trust" → DST. Run.

2. "Will I receive a loan against the installment note?"

If yes → Monetized Installment Sale. IRS listed transaction.Absolutely walk away.

3. "What's the IRC code section that authorizes this structure?"

Acceptable answers: IRC §453 (SIS), IRC §664 (CRT), IRC §1031 (LKE / DST-fractional). Unacceptable: "well, it's based on §453 by analogy" or "there's case law that supports it." If the answer isn't a clean code section, ask a tax attorney before signing anything.

Want a second opinion?

If your CPA flagged "installment sale" as risky — they're probably thinking DST.

The SIS uses straight IRC §453 the same way installment sales have worked for a century. Different code, different risk. Happy to walk your CPA through it directly — most are relieved within the first 10 minutes once they realize the carrier-assignment structure isn't anything like a DST.

Call Hans · 213-414-2808 CPA Briefing Page →