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...

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...

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 this short essay I make 10 modest suggestions for bringing Trusts & Estates to the front and center of American legal education. Many students take the basic school T&E course with some sense that it is part of a well-rounded legal education, but the field has a reputation for being staid,...

Intrafamilial arrangements labeled as loans have long invited special scrutiny from the Internal Revenue Service. In some cases, the IRS has successfully established that the arrangement was not a loan but another type of transfer, such as a gift. In the wake of several IRS victories in cases...

This article explores the gift tax consequences of an exchange of promissory notes between family members when interest rates have dropped from when the original or old note was issue to the present time when the new note is issued. More specifically, the scenario contemplated involves two...

This short column highlights for estate and gift tax practitioners 10 noteworthy law review articles published during 2010. Estate and gift taxation is one area in which law professors’ writing should be of interest to tax practitioners and vice versa, because significant change in the law of...

The law of wills, trusts, and estates could benefit from consideration of its development and impact on people of color; women of all colors; lesbian, gay, bisexual, and transgendered individuals; low-income and poor individuals; the disabled; and nontraditional families. One can measure the...

Gifts of tangible personal property and closely-held business interests typically are made without a paper trail (e.g., cancelled check or deed recording). Because gift tax returns are not due until April 15 of the calendar year following the transfer, a non-compliant taxpayer can game the...