The untimely death of Michael Jackson this past June presents an opportunity to reassess certain thorny estate tax issues that may arise when a celebrity dies owning valuable intellectual property. Elsewhere we have debated hypothetical, tax-motivated changes to state laws relating to postmortem...

This article examines the changes that philanthropist Brooke Russell Astor made to her will – or, more accurately, the changes that Mrs. Astor purportedly made to her will – before her death in 2007. Anthony Marshall, the 85-year old son of Brooke Astor, and lawyer Francis X. Morrissey, who...

The focus of this article is the federal estate and gift tax treatment of copyright termination rights. The right of a creative individual to terminate prior copyright transfers serves to protect against economic exploitation. Once a copyright’s value has been established in the marketplace,...

Anyone who has spent time in cyberspace understands the concept of an alter-ego. In on-line games, chat rooms and on the internet generally, users select one or more avatars to represent themselves. Avatars function as the end-user's alter-ego. The avatar may be a three-dimensional character in...

What are the constitutional limits on a state's power to tax a trust with no connection to the state, other than the accident that a beneficiary lives there? The Supreme Court of the United States will take up this question this term in the context of North Carolina v. Kimberley Rice Kaestner...

In their contributions to the Symposium on The Centennial of the Estate and Gift Tax, Professor Joseph Dodge, Professor Wendy Gerzog, and Professor Kerry Ryan offer concrete proposals for improving the existing estate and gift tax system. Professor Dodge and Professor Gerzog are especially...

In the last decade, grantor trusts have become a cornerstone of many sophisticated estate plans. Although clients and their advisors employ grantor trusts with great frequency and success, few taxpayers and not all estate planning professionals are fully conversant with the income tax reporting...

This short review essay evaluates the Practicing Law Institute's Circular 230 Deskbook by Jonathan G. Blattmachr, Mitchell M. Gans and Damien Rios. For attorneys, accountants and others who practice before the IRS, the Circular 230 Deskbook is a masterful analysis and an important guide to the...

Prior to 2011, the most efficient estate tax planning for married couples required a minimal level of asset equalization. In order to take maximum advantage of all existing wealth transfer tax exemptions and credits, each spouse needed to own, in an estate tax sense, enough assets to be able to...