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