Inter-family sale and gift transactions will increase following recent taxpayer victories using formula allocation clauses. These cases provide a roadmap to mitigate the gift tax risk associated with such transactions. Sale transactions are also likely to increase if a 10-year minimum GRAT term is imposed.
This program will focus on the alternatives for the "donee" of the excess value under a Petter type of formula allocation clause, which include among others a public charity, donor advised fund (DAF), private foundation, zeroed out CLAT, inter vivos QTIP, GRAT, defective gift trust, and spouse.
Our
panelist will include representatives of two major donor advised funds,
Fidelity Charitable Gift Fund and Community Foundation for the National
Capital Region and the lead litigation counsel for McCord, Christiansen andPe
Their presentation will include a review of other practical considerations, including the risk of IRS challenge and the exercise of ownership rights and tax reporting during the determination period.
OUR EXPERTS
MODERATOR:
- Richard S. Franklin, Law Office of Virginia A. McArthur, Washington, DC
PANELISTS:
- John W. Porter, Baker Botts LLP, Houston, TX
- Karla D'Alleva Valas, Fidelity Investments Charitable Gift Fund, Boston, MA
- David Bradt, WTAS LLC, McLean, VA & Chairman, Board of Trustees for the Community Foundation for the National Capital Region
Event Type: Teleconference and Live Audio Webcast
Event Code: RP1TPF
Leave a comment