Gift tax rules are not relevant to the question whether the transfer has the requisite donative intent for the income tax exclusion.

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The income tax exclusion for U.S. citizens and resident aliens abroad was put into law about a quarter-century ago partly to encourage U.S. companies to send U.S. workers overseas.

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Today, the income tax exclusion perversely gives the biggest benefit to those who make the most money and the smallest to those who earn the least and need the most help paying for insurance.

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