March 15, 2010

Formula Clauses: Hedging Value And Legislative Risks

Tax Notes
Edward F. Koren
Estate Planning and Administration partners Edward Koren and Milford Hatcher authored a Tax Notes article titled, "Formula Clauses: Hedging Value And Legislative Risks."

Recent court decisions have upheld certain deferred value formula clauses as effective hedges against valuation adjustments by the IRS. Similar formula clauses may also protect against a possible retroactive reinstatement of the generation-skipping transfer tax. The article discusses the uses and limits of formula clauses as valuation and retroactive GSTT legislation hedges. To view the full article please visit the link below.

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