Practical Drafting is coming “in-house” to Carter Ledyard & Milburn LLP and will be published periodically by the firm without a fixed schedule. It will cover matters of general interest to clients of the firm and other lawyers, accountants and interested parties. The coverage will include trust and estate matters, federal tax matters and state matters of general interest. The authors are Richard B. Covey and Jerome Caulfield, two senior partners who have had long experience with the firm. They were the authors of the brief filed with the Tax Court in Walton v. Comm’r, 115 T.C. 589 (2000). The case rejected the IRS position and approved zeroed-out GRATs. We believe the Biden administration may propose a change which will, in effect, eliminate that concept. The Obama administration proposed such a change but failed to enact it.
The first substantive issue of the “new” Practical Drafting will be posted soon to this site and it will cover a proposal from the Biden administration: “Taxing Unrealized Appreciation on Lifetime Transfers and at Death”.
Practical Drafting® is published by Carter Ledyard & Milburn LLP. It is intended to provide information and guidance with respect to specific topics of interest to trust and estate lawyers and other professionals practicing in the field. It is not intended to provide individualized legal or other professional advice, and should not be used as a substitute therefore. Neither the authors, the editorial staff nor the publisher of Practical Drafting® assumes any liability for the accuracy of its contents.
The statements in this issue cannot be used by any taxpayer to avoid tax penalties. The previous sentence is inserted pursuant to U.S. Treasury Regulations governing tax practice.
Practical Drafting® may not be reproduced without the express permission of the publisher. For questions regarding subscriptions, please contact us at email@example.com.