Questão jurídica principal
Whether annual waivers up to the gift-tax exemption could be treated as tax-free staged gifts
Decisão extraída
No. The whole amount was taxable because the plan from the outset was to forgive a much larger total debt.
Fundamentação extraída
The statute and legislative materials did not authorize splitting a preplanned gift into annual exemption-sized installments; the economic reality was a single intended gift of CHF 225,000.