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Monetized installment sales: the deferral pitch the IRS has been watching

The honest short answer

The pitch: sell your appreciated business or real estate, get nearly all the cash immediately through a "monetization" loan, but defer the capital gains tax for years or decades under installment-sale rules, as if you'd only received a small down payment. A genuine installment sale under §453 — where the seller actually carries a note and receives payments over time — is completely legitimate. The "monetized" version, where a seller nominally reports a deferred sale while a related intermediary immediately hands them 90%+ of the value as a "loan," is exactly the kind of structure the IRS has flagged as a transaction of interest and has been actively scrutinizing. If you're getting nearly all your money now, tax deferral premised on not having received it should raise real questions.

What's legitimately true in the pitch

  1. Ordinary installment sales are real and common — a seller who genuinely carries a note and collects principal and interest over years defers gain recognition to when payments are actually received.
  2. Deferring a large gain has genuine value when the deferral is real: time value of money, potential future rate changes, and the ability to spread income across years.
  3. Legitimate intermediary and escrow structures exist in real estate and business sales generally, separate from the aggressive monetized version being scrutinized.

Where the pitches mislead

The math the pitch never runs

Compare a genuine installment sale — where you actually wait for the payments — against a monetized version where you get the cash immediately but the "loan" is functionally the sale proceeds. If the answer to "what would happen to my tax position if this were audited and recharacterized as a sale in the year I received the cash" is "a large tax bill plus interest and penalties, potentially plus promoter-related exposure," the deferral being sold isn't worth the risk for most sellers. Ask what percentage of sellers who used a comparable structure have been audited, and what happened.

Questions to ask before signing

Our position: a real installment sale, where you genuinely wait for the money, is a sound and legal deferral tool. A structure engineered to get you the cash immediately while claiming you haven't received it is the exact pattern the IRS has named as a transaction of interest — treat any pitch built around that gap with real skepticism.

Selling a business or investment property and want real deferral options?

We'll lay out the legitimate installment sale, 1031, and trust structures that actually hold up before you consider anything flagged by the IRS.

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This review discusses a category of tax marketing generally, not any specific company or offering, and is not investment, legal, or tax advice for any particular situation.