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Understanding the Reciprocal Trust Doctrine and Its Impact on Estate and Gift Taxation 

The reciprocal trust doctrine is a critical consideration in estate planning for high-net-worth individuals (HNWIs) aiming to maximize the current gift and estate tax exemption before its reduction in 2026. This doctrine prevents spouses from creating trusts for each other that allow them to retain lifetime enjoyment of assets while avoiding estate tax inclusion. To mitigate risks, many HNWIs utilize Spousal Lifetime Access Trusts (SLATs), but careful structuring is essential to avoid triggering the doctrine. Proper planning, such as introducing variations in trust terms or utilizing different jurisdictions, ensures the intended tax benefits remain intact.

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