What is the minimum capital gain for each product?

The 537 IST is typically used for capital gains of $1M or more, which is the threshold for basis extraction eligibility. The Structured Installment Sale is available starting at approximately $100K in capital gains, making it accessible to a much wider range of sellers.

Can I access my money immediately with either product?

The 537 IST offers full liquidity with access to funds within 3–7 business days and no surrender charges. The SIS ties payments to the selected note terms (5, 10, 15, or 20 years), though custom liquidity strategies may be negotiable with the trustee.

What is basis extraction and which product offers it?

Basis extraction allows you to receive your original cost basis (purchase price + improvements) tax-free at the time of the transaction. This is available only with the 537 IST for trusts valued over $1M. For investment properties, up to $500K of basis can be extracted. The Structured Installment Sale does not offer basis extraction.

Do both products work with the same IRS rules?

Yes. Both the 537 IST and the SIS are founded on IRC Section 453 (installment sales) and IRS Publication 537 (installment sale reporting). Both avoid constructive receipt by directing proceeds to a trust rather than to the seller.

Can I refinance a 537 IST note to extend the deferral?

Yes. One of the key advantages of the 537 IST is the ability to refinance the promissory note at maturity, effectively extending the tax deferral period. Combined with step-up in basis at death, this can eliminate the deferred gain entirely for heirs. The SIS uses a fixed-term note selected at inception.

Which product is right for selling a dental practice worth $800K?

For a business sale with $550K in capital gains (like a dental practice purchased for $250K and sold for $800K), the Structured Installment Sale is the ideal fit. The gain falls within the $100K–$1M sweet spot, and the 3-step process is designed for straightforward business sales. If the gain exceeds $1M, the 537 IST would provide additional benefits like basis extraction and full liquidity.

Which product is right for selling a $3M commercial property?

For a large real estate transaction with significant capital gains, the 537 IST is the better choice. It offers basis extraction (receive your original cost basis tax-free), full liquidity, investment management via the Model Q strategy, and the ability to refinance the note to extend deferral. The SIS is designed for smaller transactions.

Does Iron Gate Holdings offer both products?

Yes. Iron Gate Holdings is one of the only providers that offers both a full Installment Sale Trust (537 IST) for larger transactions and a Structured Installment Sale (SIS) for smaller ones. This means your advisor can recommend the right product for your specific transaction size and needs — no competitor offers this same range.

Can I start with a SIS and upgrade to a 537 IST later?

Each transaction is structured independently, so a completed SIS cannot be converted to a 537 IST. However, if you sell additional assets in the future with gains exceeding $1M, those transactions can be structured using the 537 IST. Many clients use the SIS for their first transaction and the 537 IST for subsequent larger sales.

537 Installment Sale Trust vs. Structured Installment Sale

Q: What is the difference between a 537 IST and a Structured Installment Sale?

Both use IRC Section 453 to defer capital gains taxes, but they serve different transaction sizes and offer different levels of control. The 537 Installment Sale Trust is designed for capital gains of $1M+ with full liquidity, basis extraction, and investment management via the Model Q strategy. The Structured Installment Sale serves gains of $100K–$1M with a streamlined 3-step process and fixed interest rates of 5–7%.

The 537 Installment Sale Trust (IST) and the Structured Installment Sale (SIS) both defer capital gains taxes under IRC Section 453 — but they serve different transaction sizes and offer different levels of control. The 537 IST is designed for capital gains of $1M+ with full liquidity, basis extraction, and investment management. The SIS serves gains of $100K–$1M with a streamlined 3-step process and published fixed rates of 5–7%. Iron Gate Holdings is one of the only providers that offers both products, allowing your advisor to recommend the right structure for your specific transaction.

Quick Decision Guide

Choose the Structured Installment Sale if:

✓Capital gain is between $100K and $1M
✓You want predictable fixed rates (5–7%)
✓You prefer a simple, 3-step process
✓You want structured quarterly income on a set schedule
✓Basis extraction is not needed

Choose the 537 IST if:

✓Capital gain is $1M or more
✓You need immediate liquidity (3–7 day access)
✓You want basis extraction (receive cost basis tax-free)
✓You want professional investment management (Model Q)
✓You want to refinance the note and extend deferral indefinitely

Side-by-Side Comparison

Feature	537 Installment Sale Trust	Structured Installment Sale
Ideal Capital Gains	$1M+	$100K – $1M
Payment Terms	Custom structured (10-year standard, refinanceable)	5, 10, 15, or 20 years (fixed at selection)
Tax Control	Complete — access to basis extraction, refinancing, and deferral extension	Structured deferral — taxes spread proportionally across installments
Liquidity	Immediate access available (3–7 business days)	Tied to note terms; custom strategies negotiable
Investment Strategy	Model Q dual-asset strategy (ETFs + Fixed Index Annuity)	Trust-managed with fixed interest rates
IRS Foundation	IRC Section 453 / IRS Publication 537	IRC Section 453 / IRS Publication 537
Process Steps	4 steps (asset transfer, trust sale, investment, income stream)	3 steps (note issued, funds enter trust, income begins)
Step-Up in Basis	Yes — promissory note qualifies as security	Potential — trust structure supports estate planning
Basis Extraction	Available for trusts over $1M (up to $500K for investment property)	Not available
Note Refinancing	Yes — can refinance to extend deferral indefinitely	Fixed term selected at inception
Best For	Large, complex transactions needing maximum control	Small-to-mid business and real estate sales needing streamlined deferral

What Both Products Share

Same IRS Foundation

Both rely on IRC Section 453 and IRS Publication 537 for installment sale treatment.

Same Trusted Team

Managed by the same team of attorneys, CPAs, and advisors at Iron Gate Holdings.

No Constructive Receipt

Proceeds go directly to the trust — you never take constructive receipt of the funds.

Trust-Based Structure

Both use a fiduciary trust with segregated assets and professional administration.

Estate Planning Benefits

Both support step-up in basis potential and trust transfers to heirs.

Compliance Track Record

3,800+ combined transactions across both products with zero IRS audit issues.

Frequently Asked Questions

Explore Further

Trust vs. Annuity SIS

How trust-based and annuity-based SIS structures compare

Case Studies

See real examples of SIS transactions for real estate and business sales

Revenue Estimator

See your personalized SIS income projection

Pro Forma Report

Generate a detailed financial analysis for your transaction

Not Sure Which Product Fits Your Transaction?

Run your numbers through our Revenue Estimator or speak with our team to determine whether the SIS or 537 IST is the right fit.

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This content is for informational purposes only and does not constitute tax, legal, or financial advice. Capital gains tax laws are subject to change. The 537 Installment Sale Trust and Structured Installment Sale are separate products with different eligibility requirements. Consult your CPA, tax attorney, or financial advisor before making any tax deferral decisions. Iron Gate Holdings does not provide tax or legal advice. IRS Code Section 453 and Publication 537 govern installment sale treatment.