Over time, your client will be able to deduct the full value of the gift to the charity from his/her income taxes. The fact that a charitable remainder trust makes payments to him/her or some other beneficiary for years does not change this rule. The value of the gift to charity is not the property’s value when it is placed inside the charitable trust.
A federal gift tax return should be filed along with the regular income tax return by April 15 if taxpayer has made:  nonexempt gifts over the amount of the annual exclusion to any person or organization during the previous taxable year or  gifts over the amount of the annual exclusion to a tax-exempt organization during the previous taxable year. No tax is assessed for such tax-exempt gifts, but the IRS still requires a return.
The statute of limitations is the period within which an action may be taken by the IRS on a tax return. After the statute of limitations has run out on a given tax return, the government cannot assess additional taxes, and the taxpayer cannot amend the return to request a refund. In general, statute of limitations for a return runs for 3 years from the date the return was filed or return due date, whichever is later.
There are 18 states (plus D.C.) that have an estate tax lower than the federal amount; only Connecticut has a gift tax (for annual gifts > $14,000), according to CCH.