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Gift-splitting: the intricacies of [section] 2513 of the Code.

Many practitioners assume that they have a full understanding of the gift-splitting provisions place in [section]2513 of the Internal income Code of 1986, as amended, and the gift tax regulations promulgated thereunder. In fact, the laws surrounding gift-splitting are mingled and an election to gift-split or the failure to suitably gift-split can cause unintended adverse tax results When practicing in the field of estate and gift taxation, a practitioner should have a clean understanding of the requirements that must be satisfied in order for a married two to properly elect to gift-split, as well as the consequences of such an ...


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