However, in order for the annual exclusion to apply, the gift must be a present interest rather than a future interest
in the property.
The Seventh Circuit affirmed the Tax Court decision that the Hackls' gifts of LLC membership interests were gifts of future interests
and as such did not qualify for the annual gift tax exclusion.
For use in course or exam preparation, this volume aids law students in recognizing and understanding the basic principles and issues of wills, trusts, and future interests
2503(b), the first $11,000 of gifts (other than gifts of future interests
in property) made by a donor to any donee during a calendar year are excluded from the total gifts made during such year.
In revenue ruling 71-443, the IRS adopted this reasoning in holding that gifts to corporations were gifts of future interests
During the transition phase the corporation intends to relocate head office operations to Houston, Texas, the energy capital of the US, a location central to the company operations, producing properties, and future interests