[EstGift] [filtered] Fall Meeting, OBBB and Subcommittee [IMAN-WEALTHMGMT.FID578316]

Tue Aug 5 07:15:49 PDT 2025

Dear Committee Members,

I hope everyone is having a nice summer.  As we roll into the dogdays of August, I had a few items I wanted to bring to your attention.

Fall Meeting

The first is the upcoming Fall Meeting in Austin.  Our meeting is scheduled for Thursday, October 23rd at 8 am.  I look forward to seeing many of you there.  Please let me know if you have any suggestions for topics or issues that you would like to see added to the agenda.  Making suggestions does not mean you have to serve as the discussion leader (but you are welcome to do so).

Also, if anyone is willing to volunteer to serve as secretary for the meeting, that would be great.

OBBBA

There is a meeting about ACTEC Comments on the OBBB on August 22 to address, among other things, some of the below issues that Beth Kaufman reported were raised at the AICPA meeting:

  *   Was the limitation of deductions to the 35% rate apply to trusts and estates?  It appears to, but was that intentional or should there be a technical correction?
  *   How about the 0.5% floor for charitable contributions?  Seems not to apply unless there is UBI.  Was that what Congress intended?
  *   Does a contribution to a Trump Account count as an annual exclusion gift?  It seems like it doesn't (but it should).  Doesn't read like a present interest.  Could it be treated like a 2503(c) trust?  Does this qualify for a technical amendment?

Steve Gorin has asked that anyone wishing to join that call email him for an invite.  In addition, please let Steve and me know if anyone would like to help write comments about the annual exclusion for Trump Accounts.

Subcommittee

For those of you who were with us in Montreal this summer, I noted that we are putting together a new subcommittee to respond to Notice 2025-19 relating to regulations potentially described in EO 14219 that may be (i) unconstitutional, (ii) based on unlawful delegations of legislative power, and (iii) those based on anything other than the best reading of the underlying statute.  Please let me know if you would like to participate in this subcommittee and if also if you are interesting in leading the subcommittee.

Best,
-Kim

Kimberly E. Cohen
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Choate, Hall & Stewart LLP
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