The Christiansen Case and the Use of Formula Clauses CLE
The American Bar Association Section of Real Property, Trust and Estate Law and the ABA Center for Continuing Legal Education are sponsoring a teleconference and live audio webcast on March 26, 2008 entitled The Christiansen Case and the Use of Formula Clauses.
Here is a description of this program:
Defined value clauses and formula clauses have long been used in estate planning. The IRS has often challenged them when they result in shifting assets or value in a way that minimizes or eliminates federal transfer taxes. In Christiansen v. Commissioner, the Tax Court approved a formula disclaimer based on reasoning applicable to defined value clauses more generally. Attend this teleconference and live audio webcast to learn:
- How defined value clauses and formula clauses work and the differences between different types of clauses
- How the IRS and the courts have viewed these clauses in the past
- What the Christiansen decision may mean for defined value and formula clauses
- Alternative methods of reducing valuation risk, including the use of consideration definition clauses
- How to effectively use these clauses in your client’s planning
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