The customer applied for ALTCS for the first time on October 18, 2015. During the application process, it is discovered that he gave a vacation property to each of his children on their 30th birthdays. His oldest daughter turned 30 in June 2010, and the customer transferred the title to her on June 17, 2010. His other daughter turned 30 in August 2012, and he transferred the title to the second property to her on August 3rd, 2012.
The customer’s look back period goes back to 09/1/2010.
Since the earliest transfer to the oldest daughter happened before 10/1/2010, it is before the look-back period. The second transfer is after 10/1/2010 and must be evaluated as a transfer.