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Description
This presentation will explore the basic principles and practical application of the adequate disclosure rules for federal gift tax reporting. The discussion will include an overview of the adequate disclosure rules in the relevant Internal Revenue Code, Treasury Regulations, and court cases. We will then apply these rules to the most common fact patterns in which adequate disclosure requirements arise and discuss the role of and requirements for valuation reports. Finally, the presentation will address situations in which compliance with the adequate disclosure rules may not be possible or practical, guiding practitioners on the analysis to perform in determining whether, and to what extent, they should disclose transfers on a Form 709.
Learning Objectives
- Review the Internal Revenue Code rules and regulations and important case law for adequate disclosure of gifts.
- Identify situations in which adequate disclosure may be required or preferred.
- Understand the basic requirements for adequate disclosure on gift tax returns (Forms 709).
- Apply the adequate disclosure reporting requirements to various types of gifts.
- Recognize scenarios where additional information and support may be needed.
- Walk through practical scenarios when adequate disclosure may not be possible.