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. The ITTP Group is actively engaged in commenting on the proposed regulations and educating our members on these changes.
Comments. An “all star” team has been 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) will review 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) are not only commenting but also shepherding the comment project. Many others will play a supporting role. The comments are due November 2nd and will be posted to the ITTP Group’s webpage when submitted.
Committees in the Income & Transfer Tax Planning Group