American Bar Association
Income and Transfer Tax Planning Group

Income and Transfer Tax Planning Group


This group concentrates on the three federal transfer taxes (estate, gift, and generation-skipping), on the income taxation of trusts, estates, grantors, and beneficiaries, and on tax litigation and controversy. Because these areas of focus comprise the federal tax universe in which most estate planning instruments operate, this group seeks to assist trust and estate attorneys in their constant endeavor to improve their knowledge of these taxes, to stay abreast of ways in which they are changing, to play a role in the development of these tax systems, and to explain how planning can impact later tax disputes. Group members work to improve the transfer tax system by preparing and submitting comments on proposed legislation and proposed regulations, and by suggesting legislative solutions to technical problems.

As the estate planning community knows, on August 4, 2016, the government issued proposed regulations under IRC § 2704 aimed at limiting valuation discounts in family controlled entities. An “all star” team was assembled on behalf of the RPTE Section to provide comments on the proposed regulations, including Richard Dees (McDermott Will & Emery, Chicago, IL), Steve Akers (Bessemer Trust, Dallas, TX), David Handler (Krikland & Ellis LLP, Chicago IL), Todd Angkatavanich (Withers Bergman LLP, New Haven, CT), Dan McCarthy (Wick Phillips Gould & Martin, LLP, Fort Worth, TX), the Stephanie Loomis-Price (Winstead PC, Houston, TX), William Sanderson (McGuire Woods LLP, Washington, DC), Jim Hogan (Andersen Tax, Washington, DC), Ron Aucutt (McGuire Woods LLP, Tysons, VA), Lou Mezzulo (Withersworldwide, Rancho Santa Fe, CA), Nathan Brown (Proskauer), Dana Foley (Proskauer) and Eric Fischer (Withers). Dennis Belcher (McGuire Woods LLP, Richmond, VA) reviewed the comments on behalf of the Section’s Trusts and Estates Governmental Submissions Committee. Ryan Walsh (Co-Chair of the ITTP Group’s Estate and Gift Committee, Hamilton Thies & Lorch LLP, Chicago, IL) and Christine Quigley (Schiff Hardin LLP, Chicago, IL) not only assisted with the commenting but also shepherded the comment project. Many others played a supporting role. The comments were submitted by the due date of November 2, 2016 and are posted below.

Committees in the Income & Transfer Tax Planning Group

Group Calls

Please join our periodic toll-free calls to discuss current developments, practical advice regarding how members handle issues that arise in this area, and issues of special interest. Reminders, including discussion topics and dial-in information, are sent to Group members and members of its committees a few days before each call. Please sign up as either a member of the Group or as a member of one of the committees to receive confirmation of the time and call-in instructions.

One of our five Committees "hosts" each call, typically with Committee members covering timely topics of interest to all Group practice areas and all of the Committees. The calls are designed to be interactive so members can participate with questions, comments or insights.

So please mark your calendar! Our remaining calls for the year are scheduled for the third Thursdays of every other month (more or less):

Information on Our Next Group Call:

Thursday, November 17, 2016, 12pm (Central Time)

Dial-in phone #: 866 646 6488, Passcode: 725 588 7619

Please join the Estate and Gift Tax Committee for a discussion on the long-awaited proposed regulations under IRC section 2704. The discussion will focus on the comments to the proposed regulations that the RPTE Section recently submitted to Treasury. Committee co-chair Ryan Walsh and Christine Quigley will lead the discussion and audience participation is greatly encouraged. Note that Ryan and Christine are especially suited for this discussion because they led the RPTE Section's comment project.

Future Calls:

· Thursday, January 19, 2017

· Thursday, March 16, 2107

· Thursday, May 18, 2017

· Thursday, July 20, 2017

Click here visit the Group & Committee Audio Archive to listen to past group conference calls.

Meetings and Events

Section Events

    Trump Tax Proposals and their Effect on Planning


    President-elect Trump and the House Republican Leadership have proposed significant changes to the income and transfer tax systems. The proposals are similar in many ways. With Republican control of both the White House and Congress starting on January 20th and the possibility of being able to pass tax ...

    Building Blocks of Commercial Real Estate


    This 2017 RPTE Section series provides a comprehensive introduction to commercial real estate law, focusing on issues as they relate to purchase and sale agreements, leasing, financing, property insurance, and tax issues in real estate and financing transactions. The series features five 90-minute CLE ...

    Due Diligence in the Purchase and Sale of Real Estate – What to Focus on and Ignore


    Due diligence for real estate transactions is a bit of an enigma. What is its goal? What does it entail? What value does it add to a real estate sales transaction? These questions often arise for lawyers and, even more commonly, for less sophisticated (or impatient) parties. We invite you to spend ...

Related Products

LISTSERV Communication

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Franklin, Richard
Law, Lester

Council Representative:

Kwon, Julie


DeVlieger, Tracy
Salti, Rana

Committee Roster  

Modified by Richard Franklin on November 6, 2016

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