gift exclusion

问题如下：

John is a $400 million millionaire in a country with very high estate taxes, and he wants to pass all of his wealth to the next generation. His adviser suggests putting the illiquid assets into a family limited partnership, which is expected to quality for a combined lack of liquidity and lack of control discount of 25%,, and gifting shares of the partnership instead of liquid securities.

解释：

A gift of $400 million worth of the underlying assets, when gifted in the form of the FLP shares, would qualify for the $300 million gift exclusion. In addition, the FLP shares would provide the heirs with access to private equity, private debt, and other alternative investments that have significant minimum investment requirements that they may not otherwise be able to meet.