[EstGift] Estate and Gift Tax Committee Meeting - Fall Meeting

[Blattmachr, Jonathan]

Dennis: I will get back to you with more but I would recommend you put PLRs 200539001, 200539010/11/12 on the agenda--no loss of GST grandparenting for transfer by the trustee (where instruments expressly authorized it) in further trust and no cottage savings gain. 

Also, I'd like some discussion abvout how small a remainder in a GRAT can be and whether a gift tax return is due in such a case. Ellen Harrison has thought about this and, perhaps, she would lead that discussion. CF plr 2002-45-053, issued after Walton but before the Walton reg's. 

If tiMe permits, I will relate a cases I am currently working on. One involves the attempted application of Atkinson to GRATs. The other is a request for information against a practitioner in part it is claimed because he has used FLPs to reduce estate and gift tax. There are Circular 230 implications. 

Jonathan

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-----Original Message-----
From: estgift-bounces at actec.org <estgift-bounces at actec.org>
To: EstGift at actec.org <EstGift at actec.org>
Sent: Fri Oct 07 17:49:40 2005
Subject: [EstGift] Estate and Gift Tax Committee Meeting - Fall Meeting 

Hello Committee Members - Mil Hatcher and I are preparing the agenda for the Estate and Gift Tax meeting in Amelia Island later next month.  One purpose of this message is to ask you for any items of interest that the Committee should discuss.  We already have several items to cover so we should have a good meeting.  Mil and I look forward to hearing from you.  Dennis.
 

Dennis I. Belcher
McGuireWoods LLP
One James Center
901 East Cary Street
Richmond, VA  23219-4030
(804) 775-4304
Fax:  (804) 698-2012
dbelcher at mcguirewoods.com


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IRS Circular 230 Disclosure: U.S. federal tax advice in the foregoing message from Milbank, Tweed, Hadley & McCloy LLP is not intended or written to be, and cannot be used, by any person for the purpose of avoiding tax penalties that may be imposed regarding the transactions or matters addressed. Some of that advice may have been written to support the promotion or marketing of the transactions or matters addressed within the meaning of IRS Circular 230, in which case you should seek advice based on your particular circumstances from an independent tax advisor.
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