July 2008

Briefing

12/ The Candidates on Estate Tax Reform

Patricia M. Soldano, president and CEO of the Costa Mesa, Calif.-based Cymric Family Office Services, describes how the two parties’ presumed nominees for President differ on estate tax reform. But, Soldano says, whoever wins, Republican John McCain or Democrat Barack Obama, is going to have to do something.

12/ Tax Law Update

David A. Handler, partner, and Alison E. Lothes, associate, in the Chicago office of Kirkland & Ellis LLP, report on:

•Holman—the recent Tax Court decision on family limited partnerships in which the court ignored commonly used restrictions on transfers of partnership interests for gift tax valuation purposes under Internal Revenue Code Section 2703.

• Private Letter Ruling 200822001—deciding that contribution of land with a residence and a retained right to lease property does not prevent the trust from qualifying as a QPRT.

• PLR 200822003—finding that payments made pursuant to a split-dollar agreement are neither gifts nor cause insurance to be includible in the grantor’s estate.

• Proposed revisions to Treasury Regulations Section 301.7477-1—guidance provided on procedures for petitions regarding gift tax disputes.

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