T transfers T’s personal resi. dence to a trust that meets the requirements (a) Transfers of retained interests in trust—(1) Inter vivos transfers. If an indi- vidual subsequently transfers by gift an interest in trust previously valued (when held by that individual) under § 25.2702–2 (b)(1) or (c), the individual is entitled to a reduction in aggregate taxable gifts. The amount of the reduc- tion is determined under paragraph (b) of this section. Thus, for example, if an individual transferred property to an irrevocable trust, retaining an interest in the trust that was valued at zero under § 25.2702–2(b)(1), and the indi- vidual later transfers the retained in- terest by gift, the individual is entitled to a reduction in aggregate taxable gifts on the subsequent transfer. For purposes of this section, aggregate tax- able gifts means the aggregate sum of the individual’s taxable gifts for the calendar year determined under section 2502(a)(1).
Appears in 2 contracts
Sources: Property Conversion Agreement, Property Transfer Agreement