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.