GIFT TAX RETURN DISCLOSURE STATEMENT

FORM 709 ADEQUATE DISCLOSURE ATTACHMENT

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DONOR INFORMATION

Donor Name: [FULL LEGAL NAME]

Social Security Number: [SSN]

Address:
[STREET ADDRESS]
[CITY, STATE ZIP]

Spouse Name (if split gifts): [SPOUSE NAME]

Spouse SSN: [SPOUSE SSN]

Calendar Year: [YEAR]

Date of Gift(s): [DATE(S)]

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PURPOSE OF DISCLOSURE STATEMENT

This disclosure statement is attached to Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return, to provide adequate disclosure of the gift(s) described herein pursuant to Treasury Regulation § 301.6501(c)-1(f).

Adequate disclosure starts the three-year statute of limitations under IRC § 6501 for assessment of gift tax, preventing the IRS from challenging the valuation or characterization of the gift after the limitations period expires.

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SECTION 1: GIFT SUMMARY

Total Gifts This Calendar Year:

Gift No.	Donee	Description	Date	FMV	Exclusion	Taxable Gift
1	[NAME]	[DESCRIPTION]	[DATE]	$[AMOUNT]	$[AMOUNT]	$[AMOUNT]
2	[NAME]	[DESCRIPTION]	[DATE]	$[AMOUNT]	$[AMOUNT]	$[AMOUNT]
3	[NAME]	[DESCRIPTION]	[DATE]	$[AMOUNT]	$[AMOUNT]	$[AMOUNT]
TOTAL				$[TOTAL]	$[TOTAL]	$[TOTAL]

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SECTION 2: ADEQUATE DISCLOSURE REQUIREMENTS

Per Treas. Reg. § 301.6501(c)-1(f), adequate disclosure requires:

☐ A description of the transferred property and any consideration received
☐ The identity of the transferor and each transferee (donee)
☐ The relationship between the transferor and each transferee
☐ If property is transferred in trust, identification of the trust and a description of its terms
☐ If a valuation discount is claimed, a description of the method used to determine fair market value
☐ A statement describing any position taken that is contrary to any proposed, temporary, or final Treasury regulation or revenue ruling

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SECTION 3: DETAILED GIFT DISCLOSURES

GIFT NO. 1

3.1.A - Property Description

Type of Property:
☐ Cash
☐ Publicly Traded Securities
☐ Closely Held Business Interest
☐ Real Property
☐ Life Insurance
☐ Partnership/LLC Interest
☐ Other: [DESCRIBE]

Detailed Description:
[PROVIDE A COMPLETE AND DETAILED DESCRIPTION OF THE PROPERTY TRANSFERRED, INCLUDING ANY IDENTIFYING NUMBERS, SHARES, PERCENTAGES, ETC.]

3.1.B - Parties to the Gift

Donor (Transferor):
- Name: [FULL NAME]
- SSN: [SSN]
- Address: [ADDRESS]

Donee (Transferee):
- Name: [FULL NAME]
- SSN/EIN: [NUMBER]
- Address: [ADDRESS]
- Date of Birth (if individual): [DATE]

Relationship Between Donor and Donee:
☐ Spouse
☐ Child
☐ Grandchild
☐ Sibling
☐ Parent
☐ Trust for benefit of: [BENEFICIARY]
☐ Charity
☐ Unrelated individual
☐ Other: [DESCRIBE]

3.1.C - Trust Information (If Applicable)

If the gift was made to a trust:

Trust Name: [TRUST NAME]

Trust EIN: [EIN]

Date Trust Created: [DATE]

Type of Trust:
☐ Irrevocable Trust
☐ Grantor Retained Annuity Trust (GRAT)
☐ Qualified Personal Residence Trust (QPRT)
☐ Irrevocable Life Insurance Trust (ILIT)
☐ Charitable Remainder Trust (CRT)
☐ Charitable Lead Trust (CLT)
☐ Dynasty Trust
☐ Other: [DESCRIBE]

Trustee Name and Address:
[NAME]
[ADDRESS]

Summary of Trust Terms:
[PROVIDE A DESCRIPTION OF THE RELEVANT TRUST TERMS, INCLUDING BENEFICIARIES, DISTRIBUTION PROVISIONS, AND POWERS OF APPOINTMENT]

Trust Document Attached: ☐ Yes ☐ No

3.1.D - Valuation Information

Date of Gift: [DATE]

Fair Market Value on Date of Gift: $[AMOUNT]

Valuation Method Used:
☐ Public Market Price (for publicly traded securities)
☐ Qualified Appraisal (attach appraisal report)
☐ Book Value
☐ Asset-Based Approach
☐ Income Approach
☐ Market Approach
☐ Combination of Methods
☐ Other: [DESCRIBE]

Appraiser Information (if applicable):
- Appraiser Name: [NAME]
- Firm: [FIRM]
- Qualifications: [CREDENTIALS]
- Appraisal Date: [DATE]
- Appraisal Attached: ☐ Yes ☐ No

3.1.E - Valuation Discounts (If Applicable)

Were valuation discounts applied? ☐ Yes ☐ No

If Yes, provide the following:

Type of Discount:
☐ Lack of Marketability Discount: [PERCENTAGE]%
☐ Minority/Lack of Control Discount: [PERCENTAGE]%
☐ Built-in Capital Gains Discount: [PERCENTAGE]%
☐ Other: [DESCRIBE]: [PERCENTAGE]%

Pre-Discount Value: $[AMOUNT]

Total Discount Percentage: [PERCENTAGE]%

Discount Amount: $[AMOUNT]

Post-Discount Fair Market Value: $[AMOUNT]

Basis for Discount:
[EXPLAIN THE FACTUAL AND LEGAL BASIS FOR EACH DISCOUNT CLAIMED. INCLUDE RESTRICTIONS ON TRANSFER, LACK OF VOTING RIGHTS, MINORITY INTEREST STATUS, AND ANY OTHER RELEVANT FACTORS.]

Supporting Documentation:
☐ Appraisal report addressing discounts
☐ Operating agreement/partnership agreement showing restrictions
☐ Buy-sell agreement
☐ Comparable transaction data
☐ Other: [DESCRIBE]

3.1.F - Consideration Received

Was any consideration received for the transfer?
☐ No - Gift was gratuitous
☐ Yes - Describe consideration: [DESCRIPTION]

If consideration received:
- Nature of consideration: [DESCRIBE]
- Fair market value of consideration: $[AMOUNT]
- Net gift value: $[AMOUNT]

3.1.G - Split Gifts (If Applicable)

Is the donor's spouse consenting to split this gift?
☐ No
☐ Yes - Spouse name: [NAME]

If splitting gifts:
- Total gift value: $[AMOUNT]
- Donor's portion: $[AMOUNT]
- Spouse's portion: $[AMOUNT]

3.1.H - GST Tax Information (If Applicable)

Is this gift subject to GST tax?
☐ No - Donee is not a skip person
☐ Yes - GST exemption allocated: $[AMOUNT]

Skip Person Status:
☐ Grandchild or more remote descendant
☐ Trust with skip person beneficiaries
☐ Other skip person

GST Inclusion Ratio: [RATIO]

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GIFT NO. 2

[REPEAT SECTIONS 3.1.A THROUGH 3.1.H FOR EACH ADDITIONAL GIFT]

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SECTION 4: POSITIONS CONTRARY TO REGULATIONS OR RULINGS

Are any positions taken on this return contrary to proposed, temporary, or final Treasury regulations or revenue rulings?

☐ No

☐ Yes - Describe the position(s):

[DESCRIBE THE POSITION TAKEN AND THE REGULATION OR RULING TO WHICH IT IS CONTRARY. EXPLAIN THE BASIS FOR THE POSITION.]

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SECTION 5: PRIOR GIFTS

Summary of Prior Taxable Gifts:

Year	Total Taxable Gifts	Cumulative Gifts
[YEAR]	$[AMOUNT]	$[AMOUNT]
[YEAR]	$[AMOUNT]	$[AMOUNT]
[YEAR]	$[AMOUNT]	$[AMOUNT]
Prior to This Year		$[TOTAL]
This Year	$[AMOUNT]
Cumulative Total		$[GRAND TOTAL]

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SECTION 6: LIFETIME EXEMPTION CALCULATION

Item	Amount
Lifetime Exemption (2026)	$15,000,000
Less: Prior Taxable Gifts	$[AMOUNT]
Less: Current Year Taxable Gifts	$[AMOUNT]
Remaining Lifetime Exemption	$[AMOUNT]

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SECTION 7: CHARITABLE GIFTS (IF APPLICABLE)

If any gifts were made to charitable organizations:

Charity Name: [NAME]

EIN: [EIN]

Gift Description: [DESCRIBE]

Gift Value: $[AMOUNT]

Charity Status:
☐ 501(c)(3) public charity
☐ Private foundation
☐ Other: [DESCRIBE]

Charitable Deduction Claimed: $[AMOUNT]

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SECTION 8: DOCUMENTS ATTACHED

☐ Copy of trust agreement (if gift to trust)
☐ Qualified appraisal report
☐ Stock certificates or transfer records
☐ Partnership/LLC operating agreement
☐ Buy-sell agreement
☐ Real property deed
☐ Title report
☐ Financial statements (for business interest)
☐ Gift letter/assignment document
☐ Crummey notices (if applicable)
☐ Other: [DESCRIBE]

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SECTION 9: CERTIFICATION

I declare under penalties of perjury that I have examined this disclosure statement and the information contained herein, and to the best of my knowledge and belief, it is true, correct, and complete. I further declare that adequate disclosure has been made pursuant to Treasury Regulation § 301.6501(c)-1(f) for all gifts reported on this return.

Donor Signature: ___________________________________

Printed Name: [DONOR NAME]

Date: [DATE]

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Spouse Signature (if consenting to split gifts): ___________________________________

Printed Name: [SPOUSE NAME]

Date: [DATE]

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SECTION 10: PREPARER INFORMATION

Preparer Name: [NAME]

Firm Name: [FIRM]

Address: [ADDRESS]

Phone: [PHONE]

Email: [EMAIL]

PTIN: [PTIN]

Preparer Signature: ___________________________________

Date: [DATE]

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IMPORTANT NOTES

1. Statute of Limitations: Adequate disclosure starts a 3-year statute of limitations on IRS assessment of gift tax. Without adequate disclosure, the statute remains open indefinitely.

2. Appraisal Requirements: For gifts of non-publicly traded assets valued over $10,000, a qualified appraisal by a qualified appraiser is generally required for adequate disclosure.

3. Split Gifts: If electing to split gifts with a spouse, both spouses must consent and the spouse must sign the return (or a separate consent form per recent Form 709 changes).

4. GST Tax: Proper allocation of GST exemption requires separate analysis. Consider automatic allocation rules and opt-out elections.

5. Filing Deadline: Form 709 is due April 15 following the calendar year of the gift. Extension to October 15 is available if income tax extension is filed.

6. MeF Filing: Form 709 may be filed electronically through the IRS Modernized e-File (MeF) system.

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This template is provided for informational purposes and should be reviewed by qualified tax counsel before use.