Using Formula Clauses for Sales and Gifts Audio Download

    By Diana S C Zeydel, John W Porter, Steven B Gorin and William S Forsberg

    Using Formula Clauses for Sales and Gifts Audio Download

    Using Formula Clauses for Sales and Gifts Audio Download

    By Diana S C Zeydel, John W Porter, Steven B Gorin and William S Forsberg

    DO YOU HAVE CLIENTS WHO WANT TO LIMIT THE POTENTIAL FOR UNINTENDED TAXES FROM GIFTS OF HARD-TO-VALUE PROPERTY? ARE YOU WARY OF USING DEFINED VALUE CLAUSES OR FORMULAS IN MAKING LIFETIME GIFTS OR SALES? PROGRAM INFORMATION Transferring business interests and other difficult-to-value assets can be fraught with peril for taxpayers ...
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    DO YOU HAVE CLIENTS WHO WANT TO LIMIT THE POTENTIAL FOR UNINTENDED TAXES FROM GIFTS OF HARD-TO-VALUE PROPERTY?ARE YOU WARY OF USING DEFINED VALUE CLAUSES OR FORMULAS IN MAKING LIFETIME GIFTS OR SALES? PROGRAM INFORMATIONTransferring business interests and other difficult-to-value assets can be fraught with peril for taxpayers and their advisors. The IRS can assert a large gift where none was intended or where a smaller gift was intended. GRATs avoid these issues, but they are not always the most appropriate vehicle. Using a defined value formula clause can mitigate risks when a GRAT does not satisfy the client's objectives. Although the IRS rarely questions formula clauses in testamentary estate plans, it has challenged them for gifts and sales. Our panelists will discuss:
    • Transfers in which defined value formulas might be considered.
    • What has happened when the IRS has attacked them (described by a lawyer who has won the most recent high-profile cases in this area).
    • How to structure where the excess goes if the IRS adjusts the value beyond what was thought to be correct.
    A charity is often the best donee to receive any excess value. Learn the benefits of including a charity -- and the process this entails -- on March 1, 2011, when one of our panelists walks through the process with charities who have experience receiving such gifts. OF INTEREST ... Donee Selection & Practical Considerations under Petter Formula Allocation Clauses

    Product Details

    Sponsors

    Section of Real Property, Trust and Estate Law

    Product Code

    5430549AUD

    Publication Date

    11/1/2010 12:00:00 AM

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