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The New Super-Charged Pat (Power Of Appointment Trust), Wendy G. Gerzog
The New Super-Charged Pat (Power Of Appointment Trust), Wendy G. Gerzog
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This article proposes to repeal the QTIP provisions in order to collect revenue now for transfers that are essentially transfers to third parties and not to the decedent's spouse. Because there are advantages of increased flexibility attendant to a QTIP as opposed to a PAT, this article proposes to take those repealed QTIP benefits and attach them to the PAT, which would greatly enhance that marital deduction trust form. A super-charged PAT would thereby be able to preserve the decedent's GST tax exemption (like a reverse QTIP), create a decedent's by-pass trust by allowing a PAT (or a partial PAT) …
Shapiro: Palimony And The Estate Tax, Wendy G. Gerzog
Shapiro: Palimony And The Estate Tax, Wendy G. Gerzog
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In Estate of Shapiro, the Ninth Circuit held that an individual had a valid palimony claim under Nevada state law. However, the issue was whether the decedent’s estate qualified for a deduction for that claim under federal estate tax law.