Gift Planning with Formula Clauses: From Procter's Progeny to Wandry World ( Part 1)

Probate & Property Magazine: Volume 28 No. 01

N. Todd Angkatavanich is a partner in the Wealth Planning group of Withers Bergman, LLP, in Greenwich, Connecticut. Liam D. Crane is an associate at Stoel Rives, LLP, in Seattle, Washington. Stephen Putnoki-Higgins is an associate at Withers Bergman, LLP, in New Haven, Connecticut.

Although lifetime transfer planning is an important agenda item for many wealthy families, there are significant attendant risks. From a transfer tax standpoint, one of the main risks arises when a person transfers assets that are difficult to value: the IRS, or state tax authority, may challenge the value of the transferred property as reported by the transferor on the gift tax return.

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