A shareholder may wish to make lifetime gifts of, say, company shares out of a large holding or a majority holding, and the gifts will reduce the holding to a much smaller or a minority one with a much lower per-unit value. Assuming that no BPR or APR is available, and some of the gifts will be exempt and some non-exempt, it can be an advantage to make a single transfer to both exempt and non-exempt recipients rather than a series of transfers separately to the different donees on different
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