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Topic 84: Gifting Strategies - 293 F Common law exemption Crummey power (1) For use in a trust that does not satisfy the requirements of Section 2503(c) (2) Gifts placed in an irrevocable trust are a gift of a future interest, but by placing a lapsing power (Crummey power) to withdraw, a future interest is converted to a present interest A Crummey power makes a transfer to a trust a gift of a present interest 6 Tax implications A Income (1) The main reason for making a gift of income-producing property is to eliminate the income tax payable by the donor on the property For example, the tax savings are obvious when the donor is in a high income tax bracket and the donee is in a low income tax bracket (2) The age of the receiver matters If the donee happens to be a child under the age of 14, the kiddie tax will be imposed on the net unearned income of the child B Gift (1) A planned gift program can minimize a donor s overall estate, minimize gift taxes, and maximize the overall after-tax income available to a family unit during the donor s lifetime (2) Valuation of gift (a) The value of a gift is its fair market value on the date of the gift (b) Any consideration received by the donor reduces the value of the gift (3) Transfers made within three years (a) Any gift tax paid on gifts within three years of death must be added to the gross estate This is called the gross-up approach, which prevents the amount of the gift tax from escaping the estate tax (b) Gifts made within three years of death are not included in the gross estate of the donor They are treated in the same way as any other post-1976 taxable gift (ie, added to taxable estate) Exceptions to this general rule include property under Section 2036, transfers with life estate; Section 2037, transfers taking effect at death; Section 2038, revocable transfers; and Section 2042, proceeds of life insurance (4) Creation of joint ownership (see Topic 87) (a) When property is purchased with the funds of one person and titled jointly, a completed gift is made (b) The most notable exceptions to this are titling of property jointly between husband and wife and titling of joint bank accounts and United States Savings Bonds (c) In the case of a joint bank account or United States Savings Bond, a completed gift is not made until the noncontributing joint owner draws upon the bank account or surrenders part of the bond for cash (5) Exercise of a general power of appointment (see also, Topic 89) (a) A general power of appointment is subject to gift tax (versus a limited or special power of appointment) (b) A general power of appointment is the power of the holder to appoint to the holder, the holder s estate, the holder s creditors, or the creditors of the holder s estate (c) This section must be kept in mind when creating trusts with Crummey powers, as Crummey powers are general powers of appointment.

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The interface FilterChain has only one method doFilter() with two parameters: ServletRequest and ServletResponse. In case of request filtering you call it to pass control to the next filter in a chain or a servlet. For response filters this method sends the output back to the user s Web browser. The following code fragment illustrates the creation of a filter that will intercept and log all requests. After the LogFilter class is compiled, its name and mapping to the application resources has to be listed in the file web.xml (as explained in Examining the web.xml Deployment Descriptor, later in this chapter).

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Now, although it's possible to use persistent cookies very easily, as shown above, there's actually a more general way to manage sessions: with a special servlet API for session tracking The Servlet Session-Tracking API The Java servlet session-tracking API provides a transparent way for the server-side developer to easily manage session data It's closely related to URL rewriting and particularly to cookies Generally, the basic idea of this API is that it provides a layer of indirection in session management Instead of worrying about exactly how session data is managed (by cookies, by URL rewriting, etc), the server-side engineer simply uses an API that can query or store named attributes Like cookies, each attribute is essentially a name/value pair: The name is the name of the attribute; the value is associated with the attribute's value As I mentioned earlier, the beauty is in the indirection this API provides Using some method (for example, URL-rewriting or cookies), it ensures that all requests from a given client session are associated with the same unique ID Thus, the server can easily associate incoming requests with existing server-side state without having to worry about the details of how this association is accomplished The following snippet of servlet code uses the session-tracking API to add a new attribute to the current session:

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public void doGet(HttpServletRequest a_request, HttpServletResponse a_response) throws IOException, ServletException { /* Get the session object */ HttpSession session = a_requestgetSession(); /* Obtain the session ID */ String sid = sessiongetId(); /* Add a name/value pair to the current session state */ sessionsetAttribute("name", "Joe Smith"); }

Ward and Peppard 2002, Figure 1.6, p. 41.)

In summary, the main advantage of using the session-tracking API rather than something like persistent cookies directly is that it's a logical way to manage session information The server side doesn't need to know how sessions are being maintained but just that they are and that attributes can be queried and managed using the provided API Using cookies explicitly, however, is a more physical approach and ties the server-side engineer to a particular session management implementation

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