Publications
With Sophisticated Planning, Don’t Underestimate the Need for a Proper Valuation
If you are considering a transfer of wealth, then you must consider obtaining a proper valuation to go with it. In the recently issued Chief Counsel Memorandum 202152018 (the “CCA”), the IRS held that a taxpayer’s valuation of assets contributed to a grantor retained annuity trust (a “GRAT”) was inadequate and, as result, the GRAT failed and the entire contribution was deemed a taxable gift. Although this CCA cannot be cited as legal precedent, it provides a great deal of insight into the position that the IRS would have with respect to funding GRATs and possibly other estate planning vehicles when it comes to valuations.
This advisory reviews the following points:
- What is a GRAT?
- A brief overview of CCA 202152018
- IRS Position
- Considerations for obtaining a valuation
To read this advisory in its entirety, click the PDF below.
