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Taxation-Federal Estate and Gift Commons

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Elaine Hightower Gagliardi On Flipping The Lens Of Estate Planning: An Examination Of The Effectiveness Of Lifetime Transfers To Achieve Federal And State Tax Savings, Elaine H. Gagliardi 2014 Alexander Blewett III School of Law at the University of Montana

Elaine Hightower Gagliardi On Flipping The Lens Of Estate Planning: An Examination Of The Effectiveness Of Lifetime Transfers To Achieve Federal And State Tax Savings, Elaine H. Gagliardi

Faculty Journal Articles & Other Writings

Estate planners are recalibrating their planning focus in response to recent tax modifications at the federal and state levels. The need to refocus planning emanates from changes wrought by recent federal tax acts, beginning in 20011 and ending in 20132 with enactment of “permanent” provisions which increase the basic exclusion amount for federal estate and gift tax and generation skipping transfer tax exemption to an inflation adjusted $5,340,000 as of 2014,3 institute the portability election for federal estate tax purposes,4 alter the transfer tax rate to essentially a flat 40 percent,5 and eliminate the state death tax credit in favor …


A Nightmare In Elwood Estate, Phyllis C. Taite 2014 University of Oklahoma College of Law

A Nightmare In Elwood Estate, Phyllis C. Taite

Other Faculty Publications

No abstract provided.


The Tax Code's Crowdfunding Dilemma: The Temptation Of Kickstarter Creators To Use The Gift Exclusion Under Section 102(A), Eric Dietz 2014 Hamline University

The Tax Code's Crowdfunding Dilemma: The Temptation Of Kickstarter Creators To Use The Gift Exclusion Under Section 102(A), Eric Dietz

Hamline Law Review

abstract


The Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth 2014 San Jose State University

The Contemporary Tax Journal’S Interview Of Pam Olson, Stuti Seth

The Contemporary Tax Journal

No abstract provided.


Trombetta: The Two Trust Tango, Phyllis C. Taite 2014 University of Oklahoma College of Law

Trombetta: The Two Trust Tango, Phyllis C. Taite

Other Faculty Publications

No abstract provided.


What's Wrong With A Federal Inheritance Tax?, Wendy G. Gerzog 2014 University of Baltimore School of Law

What's Wrong With A Federal Inheritance Tax?, Wendy G. Gerzog

All Faculty Scholarship

Scholars have proposed a federal inheritance tax as an alternative to the current federal transfer tax, but there are serious flaws with that idea. In existing inheritance tax systems, those problems include: (1) different tax rates and exemptions based on the decedent’s relationship to the beneficiary; (2) the lack of a tax on lifetime gratuitous transfers, including gifts with retained interests or control; and (3) the persistence of most current valuation distortion abuses. In any inheritance tax model, moreover, there would be significantly decreased compliance rates and increased administrative costs because by focusing on the transferees instead of the transferor, …


The Physician Orders For Life-Sustaining Treatment (Polst) Coming Soon To A Health Care Community Near You, Robert B. Wolf, Marilyn J. Maag, Keith Bradoc Gallant 2014 Maurice A. Deane School of Law at Hofstra University

The Physician Orders For Life-Sustaining Treatment (Polst) Coming Soon To A Health Care Community Near You, Robert B. Wolf, Marilyn J. Maag, Keith Bradoc Gallant

ACTEC Law Journal

No abstract provided.


Front Matter, 2014 Maurice A. Deane School of Law at Hofstra University

Front Matter

ACTEC Law Journal

No abstract provided.


Book Review: Robespierre Meets The Foreign Tax Credit: Reflections On Piketty's "Capital In The Twenty-First Century" And The Contemporary Tax Policy Debate, Michael A. Livingston 2014 Maurice A. Deane School of Law at Hofstra University

Book Review: Robespierre Meets The Foreign Tax Credit: Reflections On Piketty's "Capital In The Twenty-First Century" And The Contemporary Tax Policy Debate, Michael A. Livingston

ACTEC Law Journal

No abstract provided.


The Terms Of The Trust: Extrinsic Evidence Of Settlor Intent, Fred Franke, Anna Katherine Moody 2014 Maurice A. Deane School of Law at Hofstra University

The Terms Of The Trust: Extrinsic Evidence Of Settlor Intent, Fred Franke, Anna Katherine Moody

ACTEC Law Journal

Each edition of the Restatement of Trusts defined the phrase "the terms of the trust" exactly the same. It means the manifestation of the settlor's intent expressed in a manner that admits of its proof in judicial proceedings. This definition weds the language of the instrument to the evidentiary rules governing Trust contests. This article explores the extent to which extrinsic evidence of settlor intent is admissable and consequently a consideration for those puzzling out the meaning of a trust.


The Persistent Preference For Inception Assets, Trent S. Kiziah, J. Clay Singleton, Stewart A. Marshall III 2014 Maurice A. Deane School of Law at Hofstra University

The Persistent Preference For Inception Assets, Trent S. Kiziah, J. Clay Singleton, Stewart A. Marshall Iii

ACTEC Law Journal

Often trusts contain assets which were formerly owned by the grantor. This article addresses whether trustees should give any preference to these assets in managing the trust portfolio. Particular attention is given to how the law has treated these assets over time and the current state of the law. For those trustees who wish to retain inception assets, the article contains practical guidelines to assist trustees.


Review: Linking The Certainty Of Death And Taxes, Browne C. Lewis 2014 Cleveland State University

Review: Linking The Certainty Of Death And Taxes, Browne C. Lewis

Law Faculty Articles and Essays

This is a review of "Wills for Everyone: Helping Individuals Opt Out of Intestacy" (53 B.C.L. Rev. 877 (2012)), by Reid Kress Weisbord. Lewis praises Weisbord’s attempt to simplify the testamentary process. She agrees with his assertion that in failing to execute a will, most people are not fearing their own mortality and instead are just not willing or able to navigate a complicated testamentary process. She supports his suggestion to make executing a will more like filing a simple tax return, when possible. In sum, she praises his efforts to reduce the rate of intestacy by simplifying the testamentary …


Van Alen: A Reasonable Consistency, Wendy G. Gerzog 2014 University of Baltimore School of Law

Van Alen: A Reasonable Consistency, Wendy G. Gerzog

All Faculty Scholarship

In Van Alen, the Tax Court held that the duty of consistency required that two of the decedent’s children use the section 2032A basis valuation figures to determine gain on the sale of their interest in the decedent’s ranch, which was left to them in trust. The siblings had argued that their stepmother erroneously completed their father’s estate tax return.


The Geography Of Marriage, William P. LaPiana 2014 New York Law School

The Geography Of Marriage, William P. Lapiana

Articles & Chapters

No abstract provided.


Front Matter, 2013 Maurice A. Deane School of Law at Hofstra University

Front Matter

ACTEC Law Journal

No abstract provided.


Ira Administration For High Net Worth Clients And Their Beneficiaries -- Unique Challenges And Best Practices For Financial Institutions, Svetlana V. Bekman 2013 Maurice A. Deane School of Law at Hofstra University

Ira Administration For High Net Worth Clients And Their Beneficiaries -- Unique Challenges And Best Practices For Financial Institutions, Svetlana V. Bekman

ACTEC Law Journal

No abstract provided.


Killing Your Chances Of Inheriting: The Problem With The Application Of The Slayer Statute To Cases Of Assisted Suicide, Ryan Konsdorf, Scott Alden Prulhiere 2013 Maurice A. Deane School of Law at Hofstra University

Killing Your Chances Of Inheriting: The Problem With The Application Of The Slayer Statute To Cases Of Assisted Suicide, Ryan Konsdorf, Scott Alden Prulhiere

ACTEC Law Journal

No abstract provided.


How To Draft Trusts To Own Retirement Benefits, Keith A. Herman 2013 Maurice A. Deane School of Law at Hofstra University

How To Draft Trusts To Own Retirement Benefits, Keith A. Herman

ACTEC Law Journal

No abstract provided.


The Intermediary Clat Alternative To The Residuary Estate Family Foundation Gift, Richard S. Franklin, Jennifer A. Birchfield Goode 2013 Maurice A. Deane School of Law at Hofstra University

The Intermediary Clat Alternative To The Residuary Estate Family Foundation Gift, Richard S. Franklin, Jennifer A. Birchfield Goode

ACTEC Law Journal

No abstract provided.


Eliminate State Tax On Trust Income: A Comprehensive Update On Planning With Incomplete Gift Non-Grantor Trusts, Kevin R. Ghassomian 2013 Maurice A. Deane School of Law at Hofstra University

Eliminate State Tax On Trust Income: A Comprehensive Update On Planning With Incomplete Gift Non-Grantor Trusts, Kevin R. Ghassomian

ACTEC Law Journal

Private letter rulings dating back to 2001 affirm various tax attributes of incomplete gift non-grantor trusts, known popularly as "DING Trusts," which have been used by taxpayers to relocate investments from high-tax states to no-tax states. In 2007, the Internal Revenue Service questioned the integrity of its rulings on the DING Trust and cast doubt on its continuing viability for tax planning purposes. After nearly six years of indecision, a flurry of favorable new rulings was released in March of 2013, restoring widespread confidence in the DING Trust as an option for taxpayers seeking relief from rising income tax rates. …


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