These changes proposed to section 2704(b) would remove legitimate valuation discounts for estate, gift, and
generation skipping taxes which businesses have used for the past two decades in order to prevent the IRS from overvaluing their businesses at death.
In addition, the
generation skipping tax has been suspended for 2010, so gifts to grandchildren and beneficiaries entirely avoid the very egregious
generation skipping tax.
His specializations include trust and estate planning, particularly
generation skipping transfer taxes and business succession planning; income tax planning and consulting; stock option planning; cash flow and risk management planning; retirement planning; education planning and charitable giving.
The rights to Howard's works were purchased from the United States based company Alla Ray Morris
Generation Skipping Exemption Trust for an undisclosed sum.
Feld (WG&L, 4th ed., 2000), provides references to important Federal estate, gift and
generation skipping tax cases and rulings rendered after 1975.
Under IRC section 7491, in any court proceeding the IRS has the burden of proof with respect to any factual issue relevant to determining a taxpayer's liability for any income, self-employment, gift, estate and
generation skipping transfer taxes if
EXHIBIT 1 DEFINITIONS TAX WHEN LEVIED Estate Tax Transfers upon death of decedent Gift Tax Transfers during lifetime of individual
Generation Skipping 1) A transfer for the benefit of a Transfer Tax - person at least two generations Direct Skip (4) below that of the transferor.
Congress included the proposal the AICPA helped develop to modify the
generation skipping transfer tax in its bill to repeal estate taxes.
On tonight's BBC1 Panorama programme he insists: "It's an extraordinary idea, abdication,
generation skipping. It isn't going to happen."
Care must be taken in preparing the Federal estate tax return, particularly with regard to the need to satisfy the exact requirements for making various elections, such as the "QTIP election," and for
generation skipping tax purposes, the "reverse QTIP election."