.@MittRomney how did romney manage to get $100 mill into family trust for his kids without incurring federal gift taxes? gifting "carried interest” rights #loophole #p2 #tcot

Wall Street Journal:  A Clue Emerges to Romney's Gift-Tax Mystery, by Mark Maremont:

One of the mysteries surrounding Mitt Romney's taxes is how the former private-equity executive managed to get $100 million into a family trust for his children without incurring federal gift taxes.

A potential clue may be found in a previously unreported 2008 presentation made by a partner at law firm Ropes & Gray LLP, which represents the GOP presidential nominee. It focuses on how private-equity executives could minimize gift and estate taxes by giving family members some of their "carried interest" rights, a major form of compensation that entitles private-equity executives to a slice of the firm's future investment profits. ...

The attorney at Ropes & Gray wrote that in the 1990s and early 2000s estate-planning lawyers "commonly advised" that executives could claim a value of zero on these transfers of carried-interest rights for federal gift-tax purposes. He said the practice ended by 2005.

rest at 

http://taxprof.typepad.com/taxprof_blog/2012/08/wsj--1.html