The Service's position more appropriately supports the argument that the receipt of a restricted partnership interest should be discounted to reflect the value at which it could presently be sold, not that only a future interest
has been received.
The IRS held in Letter Ruling (TAM) 9532001 that in a specific situation, because the right of notification of these withdrawal rights was waived and the withdrawal instructions were not furnished by the donor to the trustee, the gifts were future interests
and not eligible for the annual exclusion.
Furthermore, their reputation throughout the global business community will better represent the Company's future interests
Ordinarily, most transfers to trusts are gifts of future interests
and therefore do not qualify for the $10,000 annual exclusion.
7 million of their future interests
under these cash compensation arrangements, this group of DLJ employees will also acquire options to purchase 9,168,724 million shares of common stock at an exercise price of $27 per share.
Acacia Research intends initially to retain significant control of its present and future interests
and occasionally to sell portions to generate earnings.