The 1932 Act set gift tax rates at three-quarters of estate tax rates, a level maintained until 1976, when Congress passed the Tax Reform Act (TRA) of 1976 and created the unified estate and gift tax
framework that consisted of a "single, graduated rate of tax imposed on both lifetime gift and testamentary dispositions" .
In 2004, the EGTRRA effectively bifurcates the previously unified estate and gift tax
system (a likely result of criticism that the income tax system would suffer from widespread erosion without a gift tax).
One basic concept in planning for spouses is to ensure that each one has at least $600,000 of assets in his or her own name to preserve full use of the unified estate and gift tax
as QTIP will be used for this purpose and how much will be used to take advantage of the (unused) unified estate and gift tax
Shaines, DC NH, 4/25/01, accountants failed to inquire about prior stock transfers and their effect on a client's unified estate and gift tax