From: jeffrey E. <jeevacation@gmail.com>
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
jeevacation@gmail.com <mailto:jee=acation@gmail.com> , and des=roy this communication and all copies thereof,
including all attachment=. copyright -all rights reserved
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