Doesn't this mean that if I create, for instance, 4 accounts per child (each one a different portfolio, with a unique account number), I could shelter 16,000k? And my wife could do the same? Considering the 19,000 federal gift tax limitation, and I'm trying to front load 529 contributions to a large extent, it seems like I could shelter 38,000k per child by creating 5 portfolios per kid per parent, with my wife and I each contributing 19,000k. We could also do the same for our other kid, sheltering another 38000k, and we're up to 76,000. It seems absurd, but the Commission's ruling seems to support this.
