@tagteam you're right about I.R.C. 2035 pulling in most gifts made w/in 3 years of death. But you get the idea. Without a gift tax estate tax can be entirely avoided by gifting assets more three years before death. Even $1B, say. But with the gift tax those gifts get added back into the estate. (For taxable estates it is still possible to get large estate tax savings with gifting because future appreciation escapes estate taxation, because of discounting, etc. but then again you lose the step-up. But of course capital gains rates are low.)
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