loanback

For example, a unit-linked office may require the borrower to have part at least of his personal pension premiums invested in units in a special fund from which the office makes loans to loanback borrowers.

A prearranged loanback of the entire gift property itself (rather than just the income therefrom) may well be disregarded as being merely a grantor retained control over the property, thereby causing the entire amount of the "loan" to be included in the grantor's estate.