Gains of $1M or more
537 Installment Sale Trust
Defer 100% of capital gains taxes while converting to passive income.
The Problem
A successful sale shouldn't mean losing over a fifth of it
Sell a highly appreciated property, business, or asset outright and the tax bill arrives all at once — and the traditional answer has hard limits.
An immediate tax hit
Depending on your tax bracket, capital gains taxes can eat up over 20% of the profit — before accounting for any state-level taxes. That obligation reduces the capital available for reinvestment, retirement, or wealth preservation.
Unforgiving 1031 deadlines
If you cannot identify or close a like-kind replacement property within the 45-day and 180-day deadlines, a 1031 exchange fails and the full gain generally becomes taxable that year.
Many assets no longer qualify
The Tax Cuts and Jobs Act limited 1031 exchanges to real property — businesses and digital assets such as cryptocurrency no longer qualify for a 1031 exchange at all.
The Solution
What is a 537 IST?
The 537 Installment Sale Trust is an IRS-compliant strategy under IRC Section 453 that allows property owners to defer capital gains taxes by selling their property to an irrevocable trust in exchange for an installment note. The trust then sells the property to the end buyer and reinvests the proceeds, generating a passive income stream for the seller.
The 537 IST is built for sales with capital gains of $1 million or more. For smaller gains, see our Structured Installment Sale offering through the Iron Gate Holdings Trust.
Legal foundation
Full memorandum on IRC §453, Pub 537, and constructive receipt.
Read the Legal Memorandum →Estate planning
How the 537 IST interacts with the step-up in basis at death.
Read about Step-Up in Basis →Why 537 IST
Key Benefits
Defer 100% of capital gains taxes
Convert property equity to passive income
No 45-day or 180-day deadlines
Works in all 50 states
IRS-compliant since 1986
Estate planning and wealth transfer benefits
The Process
How It Works
From consultation to income stream — six steps, structured under IRC §453.
Property or
Business SaleEscrow &
Closing537 Installment
Sale TrustInstallment
Payments to You
Consultation
We review your property, tax situation, and goals to determine if a 537 IST is right for you.
Trust Formation
An irrevocable trust is established with an independent trustee and customized terms.
Installment Sale
You sell your property to the trust in exchange for an installment note with defined payment terms.
Property Sale
The trust sells the property to the end buyer at fair market value.
Reinvestment
The trust reinvests the proceeds into a diversified portfolio to generate income.
Income Stream
You receive regular installment payments, deferring capital gains taxes over the payment period.
Which one fits your sale?
537 IST vs. Structured Installment Sale
Two installment-method strategies, one decision point: the size of your capital gain.
537 IST
Gains of $1M or more
Structured Installment Sale
Gains under $1M
Built for
Sales with capital gains of $1 million or more.
Sales with capital gains under $1 million.
Trust structure
An irrevocable trust with an independent trustee and customized terms.
The Iron Gate Holdings Trust receives the sale funds and acts as the intermediary.
Eligible assets
Real estate, businesses, business assets, and digital assets such as cryptocurrency.
Investment property, collectibles, businesses, and highly-valued residential sales.
Your payments
A secured installment note with defined payment terms; the trust reinvests the proceeds into a diversified portfolio to generate income.
A promissory note paying a structured series of principal + interest payments over a set term — 5, 10, 15, or 20 years.
Built for
537 IST
Sales with capital gains of $1 million or more.
Structured Installment Sale
Sales with capital gains under $1 million.
Trust structure
537 IST
An irrevocable trust with an independent trustee and customized terms.
Structured Installment Sale
The Iron Gate Holdings Trust receives the sale funds and acts as the intermediary.
Eligible assets
537 IST
Real estate, businesses, business assets, and digital assets such as cryptocurrency.
Structured Installment Sale
Investment property, collectibles, businesses, and highly-valued residential sales.
Your payments
537 IST
A secured installment note with defined payment terms; the trust reinvests the proceeds into a diversified portfolio to generate income.
Structured Installment Sale
A promissory note paying a structured series of principal + interest payments over a set term — 5, 10, 15, or 20 years.
Both strategies follow IRC §453 and IRS Publication 537, and both are structured to avoid constructive receipt of the sale proceeds. We can help you compare the two based on your numbers.
A Proven Track Record
Trusted with thousands of transactions
Q-1031 Exchange Solutions is led by Kevin Brunner — a Marine veteran with 40+ years of experience in business, M&A, and financial services, leading a multidisciplinary team of advisors, CPAs, and attorneys.
Schedule a Call3,800+
successful transactions
$1.52B
in taxes deferred for clients
$400,000
average tax deferred per client
Zero
IRS audits in 20+ years
Kevin's demonstrated himself to be an expert in wealth planning and financial strategies. Kevin's approach is refreshing in that he operates with his customers' best interests in mind, and he takes the steps necessary to educate them. Kevin's sound value system, integrity, and expert knowledge make him a professional I'd recommend to others.
I have found Kevin to be easy to work with and he can clearly explain the pros and cons of the many financial options that are open to you. He can also offer innovative alternatives for your consideration which will help you get a better focus to make informed decisions on your long-term goals.
Next Step
Ready to see your numbers?
Schedule a 15-minute call to walk through your numbers with an advisor — or run the estimator yourself first.