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Background: Under IRC Sections 2 5 0 5 and 2 0 1 0 , an individual ( U . S . citizen or resident )
Background: Under IRC Sections and an individual US citizen or resident may give up to a specified amount of gift without any federal gift tax liability. The tax act, Pub. L No increased the necessary exclusion amount from $ million basic exclusion to $ million, effective after December In addition to the basic increase to $ million, under Section a generationskipping transfer tax two or more generations below the transferor may be used by taxpayers. The generationskipping transfer tax applies to gifts to or in trust for beneficiaries who are "skip persons" as to the transferor. Imagine you are working for a tax firm. A client approached you with a question about the tax consequences of setting up an irrevocable trust for his two grandchildren to attend college. Please respond to the following:Discuss the tax issues or consequences of the generationskipping provision and a direct gift to the grandchildren instead of creating the trust.Make at least two recommendations to support either a direct gift to the grandchildren or the creation of the trust.
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