Consider all possibilities when bequeathing a loan account

In one of the popular estate planning structures, estate owners were advised over the years to sell growth assets to an inter vivos trust on outstanding loan account.  Prior to the ABC case mentioned below, the outstanding amount of the loan on date of death of the seller was then bequeathed in his/her Will to the trust, thereby completing the transfer of the full value of the asset(s) to the trust.

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