Gift tax rules are not relevant to the question whether the transfer has the requisite donative intent for the income tax exclusion.

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One of the first requirements of a valid gift is donative intent.

CENTERFORSECURITYPOLICY: converter

Your advisor might encourage you to examine your conscience to make sure that you have a desire to benefit the other party, since donative intent is a requirement.

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Rolling Jubilee appears to be working on the premise that a creditor acting in an economically irrational way and wrapping forgiveness letters up in a bow establishes donative intent.

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