[EstGift] Coeur d'Alene Summer Estate and Gift Tax Committee

Milford B. Hatcher mbhatcher at jonesday.com
Mon Jun 9 06:40:37 PDT 2008


I am considering the following agenda items for the upcoming summer meeting
and am looking for volunteers as discussion leaders of the unassigned
topics.  I anticipate that there are more proposed topics than we would
have time to cover at Coeur d'Alene.  This is in hopes that the additional
options will attract new discussion leaders, in addition to the valued
recidivist discussion leaders.   Also, please feel free to let me know any
other topics which you deem to be timely and which I may have omitted from
my list.  To the extent that we have volunteers for excess topics, or to
the extent that the volunteers won't be able to attend the Coeur d'Alene
meeting, we will defer some of the topics to the Savannah fall meeting.
I'll let the respective volunteers know well in advance of the summer
meeting which topics, if any, are being rolled over.

The topics which will be discussed are the following:

1.   Recent FLP Section 2036 and Valuation Decisions: Mirowski, Holman, and
Astleford

2.   Section 2032 Anti-Kohler Proposed Regulations

3.  FLP Settlement Survey

4.  Rev. Rul 2008-22:  Nonfiduciary Substitution Powers

5.  Substitution of Lower AFR Notes for Higher Ones (Blattmachr)

6.  Section 6694 Proposed Regulations

7.  Section 529 Notice Comments

The following topics will be considered if one or more discussion  leaders
step forward:

1.  Rent Free Use of a Residence as a Gift (T. Berry?)

2.  Treatment of Holiday, Birthday, and Similar Presents as Gifts

3.  Section 2642(g) GST Tax Filing Extension Proposed Regulations and Other
Recent GST Developments

4.  FATF Update

5.  SCIN in a GRAT

6.  Topfer: Grantor's Purchase of "Binary" Options from GRAT

7.  Swallows Holding: Regulatory Deference

8.  Estate Tax Reform Update

I look forward to seeing as many of you as possible in Coeur d'Alene and to
receiving a rash of emails from volunteer discussion leaders in the
interim.  We should have a full agenda of very timely topics, and I hear
nothing but great things about Coeur d'Alene as a destination.

Many thanks.

Milford B. Hatcher, Jr.
Jones Day
1420 Peachtree Street, NE
Suite 800
Atlanta, GA  30309-3053
Telephone:   (404) 581-8510
Telecopy:     (404) 581-8330
Email:  mbhatcher at jonesday.com
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