Holzman, supra note 47, at 66-67 (one transfer was considered to be a net gift where the donees
signed letters prepared by the donor's lawyer, stating "We have further been informed that this gift is being made subject to my paying the gift tax on same.
If the income beneficiary and the remainderman are separate individuals, there are two potential donees
for the annual exclusion.
Current law allows an individual who wants to make a gift to transfer up to $13,000 per donee
, per calendar year, free of gift tax and without the requirement of filing a gift tax return.
We suggest, however, that the transition rule be included in the regulations and the regulations be clarified to state that the pledge card (in respect of all periods) need not be prepared by the donee
who have not accrued unconditional promises to give should study very carefully their past collection experience to aid in establishing an appropriate allowance for uncollectibles.
If a donor makes gifts of present interests in property and the total value of those gifts to any donee
exceeds the annual exclusion amount, the donor must generally file a Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return.
The IRS argued that Treeco's restrictions on the transferability of shares meant the donees
had little immediate economic benefit.
Although making gifts to qualified donees
is straightforward, the vast majority of them are Canadian, so this option is usually not available to groups wanting to do work abroad.
Specifically, the nonexempt donees
(the taxpayers' four sons and four generation-skipping transfer (GST) tax trusts established for their benefit) were to receive LP interests with an aggregate FMV of up to $6,910,933.
Second, the court reasoned that extending the doctrine to noncharitable donees
would encourage tax avoidance.
include registered charities, but also certain other institutions or organizations, including municipal governments and certain provincial and federal Crown agencies.
b) Upon the death of the donee
, to the extent that the donee
's estate is insufficient to satisfy the claims of creditors of the donee
's estate, property subject to a general power of appointment that was created by someone other than the donee
and that was exercisable by the donee
's will is subject to those claims and expenses to the same extent that it would be subject to those claims and expenses if the property had been owned by the donees