Your client has made previous lifetime gifts that have fully exhausted his applicable credit amount. He has asked you to advise him about the tax consequences of transferring his closely held business, valued at $350,000, to his daughter in exchange for a series of fixed single life annuity payments having a present value of $300,000. You should inform him that the most important tax implication of this intrafamily business transfer is that A)if he has received less than $300,000 from his daughter before he dies, he will have to include the present value of the difference in his gross estate.

SWFT Individual Income Taxes
43rd Edition
ISBN:9780357391365
Author:YOUNG
Publisher:YOUNG
Chapter3: Tax Formula And Tax Determination; An Overview Of property Transactions
Section: Chapter Questions
Problem 49P
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Your client has made previous lifetime gifts that have fully exhausted his applicable credit amount. He has asked you to advise him about the tax consequences of transferring his closely held business, valued at $350,000, to his daughter in exchange for a series of fixed single life annuity payments having a present value of $300,000.

You should inform him that the most important tax implication of this intrafamily business transfer is that

A)if he has received less than $300,000 from his daughter before he dies, he will have to include the present value of the difference in his gross estate.
 
 
B)he will be making a taxable gift of $50,000 because the value of the transferred business exceeds the present value of the expected annuity payments.
 
 
C)he will be making a taxable gift of $350,000 because the Chapter 14 rules require his retained interest to be valued at zero.
 
 
D)he will have to include $50,000 minus one annual exclusion in adjusted taxable gifts in his estate tax calculation as an adjusted taxable gift.
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