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.
(Note: the portability provisions do not apply to the generation skipping
tax.) This provision allows a surviving spouse to take advantage of the unused portion of the deceased spouse's exemption for the very first time in tax law history.
In addition, the generation skipping
tax has been suspended for 2010, so gifts to grandchildren and beneficiaries entirely avoid the very egregious generation skipping
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.
EVEN ESTATE PLANNING professionals sometimes struggle with the generation skipping
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."