Federal Taxation of Estates, Trusts and Gifts: Cases, Problems and Materials
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This new edition of Federal Taxation of Estates, Trusts and Gifts again blends a traditional casebook approach with a problem method, to develop student understanding of the relevant rule structure pertinent to the transfer of wealth. The transactional organization facilitates student comprehension by repeatedly exposing students to certain themes, such as reason for deductibility, taxation based on passage of economic benefit, and valuation. This Fourth Edition also uses structured problems to facilitate an understanding of the doctrinal framework, analytical processes, and policy issues. Federal Taxations of Estates, Trusts and Gifts presents a comprehensive study of the tax aspects involved in the wealth transfer process: Chapter 1 provides indispensable background on the federal wealth transfer and related income tax systems. Chapter 2 provides an overview of each of the tax systems. Chapters 3, 4, and 5 outline the basic structure of the gift, estate, and generation-skipping transfer tax systems and include an examination of underlying policy questions. Chapters 6 through 13 explore how the transfer tax systems, plus the relevant income tax rules-especially the grantor trust provisions of subchapter J-apply to various transactions, most of which are in the nature of testamentary substitutes. The income taxation of estates and non-grantor trusts and their beneficiaries is comprehensively covered in Chapter 14. The book ends with Chapter 15, which provides options for reforming, as well as alternatives to, the tax systems. The Fourth Edition contains not only the changes made by the American Taxpayer Relief Act of 2012 as well as more recent developments, but also highlights a variety of estate planning considerations. While relying on well-recognized leading cases, it also includes recent and significant cases, rulings, and regulations that either break new ground or expand on existing law.
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Table of Contents
Part I Introduction
Chapter 1 Background
Chapter 2 Overview of Federal Taxation of Estates, Trusts, and Gifts
Part II Basics of Wealth Transfer Taxation
Chapter 3 Estate Taxation Basics
Chapter 4 Gift Taxation Basics
Chapter 5 Generation-Skipping Transfer Tax Basics
Part III Application of Principles
Chapter 6 Transfers Near Death
Chapter 7 Retained Interest
Chapter 8 Revocable Transfers
Chapter 9 Retention of Powers Other Than the Power to Revoke
Chapter 10 Life Insurance
Chapter 11 Annuities and Other Retirement Arrangements
Chapter 12 Third-Party Powers
Chapter 13 Concurrent Property Interests
Chapter 14 Income Taxation of Estates, Trusts, and Beneficiaries
Part IV Policy Considerations
Chapter 15 Perspectives on the Current Wealth Transfer Tax System
Table of Cases
Table of Statutes
Table of Agency Decisions