Alex owns 60% of the Hot Wheels LLC, which is treated as a partnership. He plans to give 15% of the LLC (one-fourth of his interest) to his daughter Haley for her high school graduation. He plans to put her interest in a trust, and he will serve as the trustee until Haley is 21. The trust will receive any distributions from the LLC, but Haley is unlikely to be given any of the cash until she is age 21. Alex’s 60% interest has a $120,000 FMV and an $80,000 adjusted basis including his $48,000 share of the LLC’s liabilities. Alex works full time for the LLC for a small salary and his share of LLC income. Alex also has a special allocation of income from rental property he manages for the LLC. What issues should Alex consider before he completes the gift?