What if the transfer agreement instead provided

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Reference no: EM133291035

Question: Darby transfers a 90 percent limited partnership interest to a trust established for the benefit of her children. Pursuant to an appraisal obtained by Darby at the time of the transfer, the 90 percent interest was worth $10 million. Concerned that the government may challenge the discounts employed in the appraisal, the transfer document provides that in the event the value of the transferred interest exceeded the $10 million value, the appropriate percentage interest as limited partner would be re-transferred to Darby. The government challenges the valuation, and successfully asserts that the value of the 90 percent interest is $18 million. As a result of this revaluation, Darby then contends that limited partnership interests valued at $8 million must be re-conveyed to her, negating any additional gift tax. Does this technique work?

a. What if the transfer agreement instead provided that a limited partnership interest representing the value in excess of $10 million would be transferred to Darby's law school alma matter?

b. What if the transfer agreement instead provided for the transfer of a 90 percent limited partnership interest, to be allocated first to the trust to the extent of partnership interests having a value of $10 million (as finally determined for gift tax purposes) with the excess passing to Darby's law school alma matter?

Reference no: EM133291035

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