Tax Facts

888 / Can married couples make a split gift for purposes of the GST tax?

Yes. If a split gift is made for gift tax purposes (see Q 905), such gift will be so treated for purposes of the GST tax.1 Split gifts allow spouses to, in effect, utilize each other’s annual exclusions and exemptions (see Q 876). One memorandum permitted a taxpayer to elect after his spouse’s death to split gifts with his spouse and thus take advantage of his spouse’s GST tax exemption where the gifts were made by the taxpayer shortly before the spouse’s death.2

1.    IRC § 2652(a)(2).

2.    TAM 9404023.

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