American Bar Association

ABA Section of Real Property, Trust & Estate Law



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 taxes 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.

Message From The Chair

Welcome to the Income and Transfer Tax Planning Group. Leigh-Alexandra Basha is the Group Chair and Carol A. Cantrell and Stephanie Loomis-Price are the Group Vice-Chairs. The Group has five substantive committees: Estate & Gift Tax; Generation Skipping Transfers; Individual and Fiduciary Income Tax; International Tax Planning; and Tax Litigation and Controversy. We appreciate your participation in the Group and look forward to working with you. The Group and its substantive committees are always in need of volunteers - for submitting comments to Treasury, for speaking, and for writing. Please feel free to contact the Group Chair ( or one of the Vice-Chairs ( or with any questions about how the Group works, how you can become involved in a Group project, or how to join a substantive committee. You may also contact one of the committee chairs or vice-chairs directly. If you have documents or links that you would like the Group to consider posting on its website, please contact Ryan Walsh (

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 with the discussion topics and dial-in information are sent to members of the Income and Transfer Tax Planning Group and its committees (Estate and Gift Tax, Generation Skipping Transfers, Individual and Fiduciary Income Tax, International Tax Planning and Tax Litigation and Controversy) a few days before the 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.

Next Group Conference Call:

Our Group Conference Call on May 15, 2014 will be hosted by the Tax Litigation and Controversy Committee.

Upcoming Calls:

Our Group Conference Call on July 17, 2014 will be hosted by the Generation Skipping Transfers Committee.


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

Related Products

Guide to International Estate Planning, A, Second Edition
An essential resource for protecting the assets and minimizing taxation of your clients, both in the U.S. and abroad
With the explosive gr... more

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Chair:  Leigh-Alexandra Basha

Council Representative:  Julie Miraglia Kwon

Vice-Chairs:  Carol A Cantrell, Stephanie Loomis-Price

Committee Roster (610 total members)

Committees In This Group Click [+] for listing


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Meetings and Events

Committee Events
2014 Spring Symposia!
May 1, 2014 - May 2, 2014
Join us in Chicago May 1-2, 2014 for the RPTE Section 25th Anniversary Spring Symposia. Noted speakers and experts in the fields of real property, trust, and estate law will be leading programs on current issues and hot topics in these areas of law.

Section Events
April 22, 2014
Location: N/A
Format: Webinar/Teleconference

April 23, 2014
Location: N/A
Format: Webinar/Teleconference

April 24, 2014
Location: N/A
Format: Webinar/Teleconference

Government Submissions

RPTE February 25, 2014 Comments to IRS on proposed 1411 regulations
Legislation Permitting Administrative Relief for Certain Late Lifetime QTIP Elections
Comments to IRS on Revenue Procedure 2001-38 in Context of Portability Planning
Portability Election Relief under Treasury Regulation Sections 301.9100-2 & 3
GST Committee September 11, 2012 Government Submission on Trust Decanting
Options for Tax Reform and Simplificaiton with Respect to Federal Estate, Gift and GST Taxes
Exhibit A to Comments on Options for Tax Reform and Simplification

Papers, Essays, and Other Resources

Same-Sex Marriage in 2014: The 21st Century Battle Between the States

Recent Cases and Rulings

Aragona Trust v. Commissioner: March 27, 2014 US Tax Court opinion on material participation by trusts
Rev. Proc. 2014-18: Automatic extension of time to make portability election
Steinberg v. Commissioner, 141 T.C. No. 8: Summary by Steve R. Akers

Helpful Links

Link to Current Form 709 Released on November 25, 2013
Link to Form 709 Instructions Released on January 18, 2014
Link to Guidance for Survivors, Executors and Administrators (Publication 559) - Released January 31, 2014
Link to IRS Frequently Asked Questions on Estate, Gift and GST Tax Issues
Rules of Practice and Procedure of the U.S. Tax Court

Modified by Ryan Walsh on April 1, 2014

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