When gifting or selling hard-to-value assets (in particular, closely held business interests) taxpayers may be concerned about unanticipated gift tax exposure where the appraised value at the time of transfer ends up being lower than the value that is finally determined by the IRS and the courts. A properly drafted and followed formula clause can be a useful planning tool to address such concerns.
Please join KPMG LLP for a webcast with professionals from our Washington National Tax practice that will discuss the following tax aspects of formula clauses in gift and estate tax planning:
- Overview of formula clauses
- Discussion of planning opportunities with formula clauses
- Examples of formula clauses used in conjunction with certain transactions (including with respect to Sales to Intentionally Defective Grantor Trusts)