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Loophole

§2503(e) — Unlimited Tuition & Medical Payments (No Gift Tax)

Pay tuition or medical bills DIRECTLY to the school/provider — unlimited, no gift tax, no exemption used.

Overview

IRC §2503(e) excludes from gift tax any amount paid DIRECTLY to a qualifying educational institution for tuition OR to a medical care provider for medical expenses, on behalf of any individual. No annual cap, no lifetime exemption used, no gift-tax return. Requires DIRECT payment — writing a check to the beneficiary that they use for tuition does NOT qualify. Stack with $19K annual exclusion for the same person. Grandparents can pay $100K/yr of grandchild's private school tuition + $19K annual exclusion cash gift = massive estate reduction.

Best fit
Grandparents funding private school / collegeHNW parents paying adult child's medical billsEstate-planning multi-generational transfers
Estimated impact
Unlimited estate reduction, potentially $100K–$millions

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