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Vol. 3 also issed as rev. 3rd ed. ; rev. 3rd edition of other vols. not planned.
This book deals with the federal income tax as it bears on gratuitous transfers and with the federal wealth transfer taxes. The federal wealth transfer taxes presently consist of a partially unified estate and gift tax and a generation-skipping tax. The federal transfer tax system is separate and apart from the federal income tax. Features: Emphasis on text, statutes, and regulations, rather than cases (especially cases that involve routine application of law to facts) "Building block" organization (simple to complex estates), rather than segmented organization according to Code sections. Extensive use of questions and problems to aid students High-profile authorship in Joseph M. Dodge (a highly regarded tax specialist), Wendy C. Gerzog, and Bridget J. Crawford (both well-established in the field) The book reconstitutes the Estate and Gift tax course from the ground up in light of modern estates practice. For example, special valuation rules are treated as basic, as opposed to being just "tacked on" as other books treat them. More emphasis on valuation and use of FLPs than in other books. Valuation is introduced early on and integrated with other material Integration of related income tax materials, including income taxation of estates and trusts Relation of tax doctrine to tax planning strategies Focus on doctrine that influences the practice of estate and trust law, rather than doctrine for its own sake Reference to state law (including recent developments) as it bears on transfer tax issues, with full coverage of issues raised by community property systems
The Logic of the Transfer Taxes: A Guide to the Federal Taxation of Wealth Transfers offers a broad survey of the federal transfer tax system. It thoroughly covers all of the fundamental rules of the gift, estate and generation skipping transfer taxes and provides numerous illustrative examples. It also offers a glimpse of some popular tax planning techniques, including FLPs, GRATS and IDGT'S, and the Special Valuation Rules of Chapter 14. It is appropriate for use as a coursebook for a two or three credit JD or LLM course, or as a reference for newcomers to the area. The Second Edition incorporates changes to the law made by the Tax Cuts and Jobs Act of 2017.
"... provides detailed coverage of the rules governing the income taxation of estates, trusts, and their beneficiaries"--Page iii.
Hardbound - New, hardbound print book.
The gift tax was first enacted in 1924, repealed in 1926, overhauled and reintroduced in 1932. At its peak in fiscal year 1999, it raised $4.6 billion in revenues, before the recent phased-in tax rate reductions ushered by the Economic Growth and Tax Relief Reconciliation Act of 2001 (EGTRRA) took effect. It is noteworthy that the gift tax was first enacted as a protective measure to minimize estate and income tax avoidance, and not for its direct revenue yield. Similarly, EGTRRA, while phasing out the estate tax, retained the gift tax for the very same reasons. Unlike the estate tax which faces an uncertain future, the gift tax is little affected by recent legislative proposals and will remain part of the tax code for the foreseeable future. Nevertheless, the gift tax has been the subject of little scrutiny and studies of its economic implications are rare. This paper is an attempt to fill this void. It traces the evolution of the gift tax since its inception, and sketches out the structure of the tax and its complex interactions with the income and estate taxes. The paper also provides an overview of the direct fiscal contribution of the gift tax, and traces the number of taxpayers over time as well as their attributes. It concludes with a discussion of the behavioral effects of the gift tax and a review of the scant literature. These include empirical evidence on the choice between gifts and bequests, timing of gifts, and compliance among others.
This comprehensive guide can serve either as a course supplement or as a refresher for members of the bar. Expert commentary summarizes the law and offers critical perspectives on the federal income taxation of estates, trusts, and beneficiaries, including the decedent's final income tax return; classification of estates and trusts; income in respect of a decedent; distributable net income; simple and complex trusts; distributions; grantor trusts; charitable trusts; and foreign trusts. Additional chapters cover basic income, gift and estate tax concepts, accumulation distributions, and specially treated trusts.