EFTA02466551.pdf

From: jeffrey E. <[email protected]> Sent: Thursday, April 21, 2016 10:03 PM To: Melanie Spinella; Brad Wechsler Subject: brad an article as per our conversation There c=n be no "additional contri butions" to a GRAT. This requirement poses no problem if a GRAT is creat=d and funded on th= same day with a single asset. However, it may not always be possible to transfer assets quickly or =t a specified tim=, especially where the client wishes to contribute multiple assets to a single GRAT. If the IRS deter=ines that the gr=ntor has made one or more addi =ional contributions, the trust will be dis qualified as a GRAT and the grantor will be deemed to have made a current gift of =/div> the trust assets (d=sregarding the grantor's retained interest) to the remainder benefi ciaries. To avoid this problem, be cer=ain to cross each t and dot each i. =C2 please note The information contained in this communication =s confidential, may be attorney-client privileged, may constitute in=ide information, and is intended only for the use of the addressee. It =s the property of JEE Unauthorized use, disclosure or copying of thi= communication or any part thereof is strictly prohibited and may be=unlawful. If you have received this communication in error, please noti=y us immediately by return e-mail or by e-mail to [email protected] <mailto:[email protected]> , and des=roy this communication and all copies thereof, including all attachment=. copyright -all rights reserved 1 EFTA_R1_01575121 EFTA02466551