<table><tr><th>From:</th><th>jeffrey E. &lt;jeevacation@gmail.com&gt;</th></tr><tr><td>Sent:</td><td>Thursday, April 21, 2016 10:03 PM</td></tr><tr><td>To:</td><td>Melanie Spinella; Brad Wechsler</td></tr><tr><td>Subject:</td><td>brad an article as per our conversation</td></tr></table>

There c=n be no "additional contri

butions" to a GRAT. This requirement poses no problem if a GRAT is creat=d and funded on th= same day with a single asset. However, it may not always be possible to transfer assets quickly or =t a specified tim=, especially where the client wishes to contribute multiple assets to a single GRAT. If the IRS deter=ines that the gr=ntor has made one or more addi

=ional contributions, the trust will be dis

qualified as a GRAT and the grantor will be deemed to have made a current gift of =/div> the trust assets (d=sregarding the grantor's retained interest) to the remainder benefi

ciaries.

To avoid this problem, be cer=ain to cross each t and dot each i.

=C2 please note

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