Step Transaction Doctrine

Year-end tax planning for 2022 is different from prior years. Practitioners might recommend traditional annual gift planning but for some (perhaps many) clients, annual gifts may not be worthwhile.

The donors, Thomas and Kim, a married couple, transferred a substantial quantity of the stock of Dell Corp. to a newly formed FLP and then made gifts of limited partnership units to a custodian for one of their children and the trustee of a…