FSP Article 2012 Sept

Defined Value Clause Offers Gift Tax Planning Certainty

Estate of Wandry v. Commissioner is the latest word from the Tax Court with regard to defined value clauses. The difference between a valid defined-value clause and an impermissible savings clause can seem metaphysical when viewed side by side in certain instances. Nonetheless, the commitment to a fixed-dollar amount satisfied the Tax Court so that Wandry now offers a blueprint for clients to follow. The Wandry case offers timely guidance, especially at this time when many wealthy clients are being encouraged to consider making substantial gifts before the end of 2012.

FSP Article 2012 Sept (Click here to download PDF)