Every advisor is aware of the importance of clients making large gift transfers before 2013. Changes to the law are expected, including a reduction in the gift and estate tax exemption amount and a limit on the time in which the generation-skipping transfer (GST) tax exemption can be allocated to produce a zero inclusion ratio for a trust. But, what can the descendants of ultra-wealthy parents do in 2012? The answer may be what we’ll call the “split-dollar legacy trust” ...

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