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. 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

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.

Although one of our five Committees "hosts" each call, each call this year will begin with a national speaker providing insights for 20 minutes, with Committee members then 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! Except for this October's call, 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:

Tuesday, October 25, 2016, 1:00p.m.ET/12:00p.m. CT Dial-in phone#: 866-646-6488 Passcode: 725.588.7619

Join the ITTP Group Call on October 25, 2016 hosted by the Tax Litigation and Controversy Committee. Jenny Johnson will speak on how to recognize the signs that a client is at risk of criminal prosecution or civil fraud penalties, how to avoid becoming an unwitting participant in the client’s fraud, and how to mitigate those risks. Ms. Johnson is a founding partner of Johnson Moore LLC in Chicago, IL, and an Adjunct Professor at Northwestern Pritzker School of Law, where she teaches Investigation, Prosecution and Defense of Tax Crimes. Abigail Rosen of Winstead PC will then moderate a discussion of recent cases that impact income and transfer tax planning.

Future Calls:

• Thursday, November 17, 2016, ESTATE & GIFT TAX COMMITTEE

• Thursday, January 19, 2017, INTERNATIONAL TAX PLANNING

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

Meetings and Events

Section Events

    Section 2704 Regulations – A Further Analysis and Action Steps


    The section 2704 regulations were released by the Treasury Department on August 3. The approach and breadth of the regulations surprised many estate planners. Our panelists will review the proposed regulations and the implications for past, current, and future planning. Topics they will cover ...

    The Digital Revolution: RUFADAA and Planning with Digital Property


    This program will highlight new developments in estate planning. The panel will present the latest non-tax hot topics and update attendees on issues relating to the revised uniform law concerning digital assets. Ownership, protection and transfer of digital assets has been an area where controversy ...

    Did You Think That Through?: The Pros and Cons of Including Arbitration Clauses in Business Contracts


    Most transactional lawyers (and their clients) assume that arbitration will reduce the cost, risk and time involved in resolving legal disputes, and will result in a fairer outcome than they would receive from a judge or jury. As a result, arbitration clauses are routinely included in business contracts. ...

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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 October 11, 2016

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