[EstGift] Presentations for Atlanta

[ZeydelD at gtlaw.com]

Dear Committee Members:
 
I would like if possible two volunteers to lead a discussion on the
following topics.
 
1.  Making the election into carry-over basis.  What are you learning
about the complexity and how are you handling the lack of guidance.
 
2.  Disclaimer planning, and in particular the mismatch between the
timing under the 2010 Act and State statutes.  I heard of one
interesting case, for example, where the attorney made a valid Federal
disclaimer, but not a valid State disclaimer.  I believe this strategy
permitted the estate to have a credit shelter trust equal to the State
exemption, then enhance it by an amount up to the Federal exemption, but
without the need to make a State only QTIP election because there was no
State gift tax.
 
3.  I also need a Secretary for the meeting.
 
Any takers before I assign some volunteers?
 
Thank you.
 
Diana

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