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H AND W HAVE A NET WORTH OF $100 MILLION. THEY ALSO HAVE TWO CHILDREN. H AND WIFE HAVE ALREADY GIFTED THEIR RESPECTIVE ESTATE AND

H AND W HAVE A NET WORTH OF $100 MILLION. THEY ALSO HAVE TWO CHILDREN. H AND WIFE HAVE ALREADY GIFTED THEIR RESPECTIVE ESTATE AND GIFT TAX EXEMPTIONS TO AN IRREVOCABLE WYOMING GIFT TRUST FOR THE BENEFIT OF THEIR CHILDREN. a. WHAT INCOME TAX STRATEGY CAN YOU RECOMMEND WHERE THE GRANTOR CAN SPEND DOWN HIS OR HER REMAINING TAXABLE ESTATE WHILE BENEFITTING THE WYOMING GIFT TRUST WITHOUT BEING CONSIDERED AS MAKING FURTHER GIFTS? TO HELP YOU OUT, THE GRANTOR RETAINED THE POWER TO REAQUIRE ASSETS AND REPLACE THOSE ASSETS WITH OTHER ASSETS OF EQUIVALENT VALUE. (PLEASE REFER TO THE GRANTOR TRUST POWERS IN 671 - 679.)

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