Re: FW: Debra Black

Eileen,

Tom Turrin sent me Debra's last gift tax return (2007). It looks like Debra has already used $1million of her gift tax credit on gifts from 1988 through 2005. As of 2007, she had used only $53,596 of her GST exemption.

Has Debra made any taxable gifts or allocated any portion of her GST exemption earlier this year?

Assuming that the answer to this question is no, Debra can gift to her new trust up to approximately $4.12 million before the end of the year without paying any gift tax. However, she has $5,066,404 of her GST exemption remaining. She may want to transfer to the new trust $5,066,404and allocate her entire remaining GST exemption to the new trust, even if it means paying gift tax (at a 35% rate) on an amount equal to the difference between $5,066,404 and $4,120,000. It may be worth it for her to pay some gift tax to enable her to get an additional $950,000 of GST exempt property into the trust.

Please let me know if you have any questions.
Elyse

no payment now

ask withers and gagosian if they can find an accomodator to take the rothko in the meantime to preserve the tax deferreal.

Ok, put that in the note I sent to Leon on Friday morn but didn't hear back. Did you speak to him on this?

Thanks Elyse, working with Jeffrey on this. Will let you know what is decided.