Making Large Taxable Gifts

This non-credit session will 1) describe which gifts might not achieve their intended objectives if certain anti-abuse regulations are adopted and which are not subject to that risk, 2) point out long-term consequences of using one’s entire exemption now, and 3) review the interaction of these tools with basis step-up issues.

The following will be discussed:

• Effect of large taxable gifts on estate tax calculation and possible disallowance of that planning for certain arrangements
• Using preferred partnership that intentionally violates Code § 2701
• Grantor retained income trusts (GRITs)
• Triggering Code § 2519 in QTIPs
• Spousal limited access trusts (SLATs)
• Basis step-up issues regarding the above ideas
• Planning for future transfers to family once lifetime gift/estate tax exemption is used up