In order to ascertain whether a disposition gives rise to a charge to inheritance tax, it will as a rule be necessary to determine the time at which the disposition takes place. As well as the non-tax implications of determining the time of completion of a gift (e.g. the competence of the donor to dispose of the property, the identity of the donee in the event of dispute), there are a number of reasons why it is important to determine for tax purposes:

(1)whether a gift has been perfected at all (¶614-950ff.);

(2)whether or not the gift is subject to a reservation (¶613-050); and

(3)when the gift was made (¶615-300ff.).

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