Extract to table
Pull the structured facts out of a document: parties, dates, amounts, obligations.
Extract to table / letter-gift-tax-coordination.docx
letter-gift-tax-coordination.docx
Parties
HARKNESS LLP
Private Client Group Strathmore Corp
Greaves LLP
Strathmore Corp
Stonecrest Realty Holdings LLC
Ashford Valuation Group LLC
Caldwell Ridgeline Capital LLC
Fund IV LP
Dates
August 1, 2023
February 15, 2023
April 15, 2023
April 15, 2025
May 1, 2023
May 1, 2026
June 1, 2023
June 1, 2026
April 1, 2023
March 20, 2023
Amounts
$60,000,000
$32,195,122
$80,000,000
$134,000,000
$29,375,859
$12,000,000
$7,800,000
$14,000,000
$9,100,000
$8,400,000
Obligations
Because the Crummey withdrawal rights create present interests in the premium contributions, the annual exclusion applies to the extent of each beneficiary's withdrawal right, up to the $17,000 annual exclusion per donee: • Number of Crummey beneficiaries: 3 • Annual exclusion per beneficiary: $17,000 • Total annual exclusion coverage: 3 × $17,000 = $51,000 Premium Funded by Annual Exclusion: $51,000 Balance of Premium Using Lifetime Exemption: The remaining $136,500 of the premium ($187,500 – $51,000 = $136,500) exceeds the available annual exclusions and constitutes a taxable gift that must be applied against Mr
However, as the return preparers, W&G must independently satisfy itself regarding these positions