The Tax Court agreed with Pierre and held that the check-the-box regulations do not "apply to disregard the LLC in determining how a donor must be taxed under the Federal gift tax
provisions on a transfer of an ownership interest in the LLC." (122) Thus, the court concluded that the "transfers to the trusts should be valued for Federal gift tax
purposes as transfers of interests in [the LLC1 and not as transfers of a proportionate share of the underlying assets of [the LLC]." (123)
(64) Thus, the minor differences between Alaska's DAPT statutes and South Dakota's initial DAPT statutes in their treatment of creditors with tort claims and creditors seeking child support and alimony could likely have been significant in either determining the federal gift tax
consequences to a settlor's transfers to the trust or in determining the federal gross estate of a settlor for federal estate tax purposes.
With regard to lifetime transfers other than a direct skip, an allocation is made on the federal gift tax
Due to the $13,000 annual exclusion and $1 million federal gift tax
exemption, no federal gift tax
Federal Gift Tax
Worksheet Current Year Q 902 Current Gifts - Annual Exclusions Q 916 - Qualified Transfers Exclusion Q 916 - Marital Deduction Q 919 - Charitable Deduction Q 920 - Total Reductions Current Taxable Gifts + Prior Taxable Gifts Total Taxable Gifts Tax on Total Taxable Gifts Appendix G - Tax on Prior Taxable Gifts Appendix G Tentative Tax Appendix G - Unified Credit Q 921 Federal Gift Tax
The tax implications also include state gift tax (only a few states have one) where applicable, which in many instances can be greater than the federal gift tax
, because of the large credit and exemptions currently available under federal gift tax
In the course of its gift tax study, SOI collected data from Federal gift tax
returns filed by individuals who gave gifts during 1997 and reported those gifts to IRS in 1998.
Chapter 17 includes the federal gift tax
(e.g., annual exclusion, deductions, and computing the tax), federal estate tax (e.g., gross and taxable estate, computing the tax, and credits), and the generation skipping tax.
Consider the merits of establishing a Grantor Retained Annuity Trust ("GRAT"), a gifting technique that could transfer future asset appreciation to family members at a reduced federal gift tax
Thus, Article 2(1)(a) makes the treaty applicable to: "In the case of the United States of America: The Federal estate tax and the Federal gift tax
, including the tax on generation-skipping transfers." [Id.] [emphasis added]
Although such contributions are considered completed gifts for federal gift tax
purposes, the annual exclusion of $10,000 per year per donee is more than sufficient to cover the annual maximum $500 contribution per donee (designated beneficiary).
unsatisfactory and contributed to enactment of a federal gift tax