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For the moment, it is possible to form what's called a zeroed-out GRAT, in which the remainder is theoretically worth nothing so that there is no taxable gift.
FORBES
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Wealth advisors have been telling clients all year that if you want to shift wealth to your kids or grandkids with a so-called GRAT, you should be doing one sooner rather than later.
FORBES: October Opportunity for GRATs and Family Loans
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If the assets put in a GRAT appreciate faster than a set rate--4% a year for GRATs set up in December 2002--you pass on assets gift-tax free.
FORBES: Money & Investing
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Then, he and his wife, Lee-Hwa, each transferred limited partnership shares into a GRAT.
FORBES: It's Never Too Early