Dean and Robin owned a family business, each holding the shares as community property. When they were divorce in 2017, the court did not force them to split the shares, citing damage to the business that could occur if the public learned that ownership of the enterprise was changing. Now it is 2020, and Robin wants to remarry. She and her new husband want to have the business retitle one-half of shares in Robins name only. The original divorce court agrees in 2020 Is this transfer subject to income tax? Is it subject to gift tax? Please provide a memo to client file.

Thank you.