Taxpayers have grappled with this dilemma of transferring a hard-to-value asset, such as an interest in a closely held business, to an irrevocable trust and risking an IRS challenge to the valuation of the transferred interest and asserting a gift tax deficiency. The most recent taxpayer victory in Wandry v. Commissioner may be a game-changer on this issue.
Wandry v. Commissioner
Wandry v. Commissioner: The Secret Sauce Estate Planners Have Been Waiting For?
Volume 26 No 6
By
Tiffany B. Carmona is a senior vice-president and associate fiduciary counsel in the Chicago office of Bessemer Trust. Tye J. Klooster is a partner in the Chicago office of Katten Muchin Rosenman LLP. This article reflects the views of the authors only and does not constitute legal or tax advice.
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