In “A Not-So-Crummey Way to Avoid Taxes: A Call for Congressional Action to Eliminate Abuse of the Present Interest Requirement,” Kristin L. Zook makes an interesting contribution to the existing catalogue of suggested reforms to the annual gift tax exclusion's present interest requirement. At the same time, she provides a useful history of the development of the scope of the exclusion and of the definition of present interest.
The annual gift tax exclusion permits a donor to make ann
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