GRAT and Valuation Planning After CCA 202152018: What Practitioners Need to Know

Accreditation Wreath Icon NC
North Carolina selected on map

North Carolina CLE
Accreditation Info

National Academy of Continuing Legal Education is a Sponsor (5258) of CLE courses, approved by the North Carolina State Bar Board of Continuing Legal Education. Attorneys may earn all required NC CLE credits from the United Institute for Continuing Legal Education. To view our full accreditation details please .

All Courses Available iOS/Android Web

All Courses Available iOS/Android Web

About This Course

The CCA 202152018, released at the end of 2021, addresses the valuation challenge regarding the consideration that should be given to a potential sale when valuing an asset. Its impact on grantor retained annuity trusts (GRATs) and how an appraiser valuates the implications of a potential sale from no sale, conversations with buyers, letters of intent, binding contracts and so forth across the continuum.

The recent changes place a possible sale fairly close to an actual sale in the procedure so that it is impossible to ignore leading the IRS to extend the reasoning in the Atkinson v. Commissioner, 115 T.C. 26, 32 (2000), aff’d, 309 F.3d 1290 (11th Cir. 2002) and held that the valuation was incorrect to such a degree that the GRAT annuity was not a qualified annuity interest as per Code Section 2702.

This resulted in the entire value of the property involved to be classified as a deemed gift. This CLE course will explain what this means to the use of GRAT’s as spillover receptacles in a defined value mechanism and what the CCA means with regards to valuations in general.

The course will review steps and strategies for practitioners and the implications for a broader application of the Atkinson principles to GRAT’s, CLT’s, CRT’s and other valuations. The course will explain how the principles might apply to penalties as well as offer a detailed discussion and analysis of the CCA.

Decorative Arc

United Makes CLE Easy

A puzzle in a hand

One.

Select Course Package

  • Unlimited CLE

    Enables you to fulfill multiple CLE cycles with one purchase.

  • One-Stop Bundles

    Our most popular courses bundled to save you time and money.

  • Build-A-Bundle

    Select the courses that interest you most while taking advantage of our bundle discount.

A clipboard with a checklist

Two.

Immediate Access to CLE Courses

Courses are available immediately upon checkout. You will have 24/7 access to your purchased courses during the lifetime of your subscription.

Courses can be started, stopped, and paused at any time.

A certificate

Three.

Instantly Print Your Certificate

You can immediately print your CLE certificate upon completion of a course.

A copy of your certificate will remain in your account and will always be accessible to you.

Decorative Arc

Want Different Options?

For a custom suite of courses, our custom CLE option satisfies your CLE cycle requirements in one easy step.

Customize OptionsRight ArrowCustomize Options