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In general, a gifting arrangement means any arrangement under which it may reasonably be considered, having regard to statements or representations made or proposed to be made in connection with the arrangement, that if a person were to enter into the arrangement, the person would: make a gift to a qualified donee, or a political contribution, of property acquired by the person under the arrangement incur a limited-recourse debt that can reasonably be considered to relate to a gift to a qualified donee or a political contribution Generally, a limited-recourse debt is one where the borrower is not at risk for the repayment. ...