This Estate and Gift Tax Rap column for Tax Notes is an extended discussion of the United States District Court (W.D. Pa.) decision in Estate of Palumbo v. U.S.. In that case, the court upheld a claimed estate tax charitable deduction for amounts passing to charity pursuant to a settlement of a...

This chart provides a visual overview of the statutory framework for the United States federal estate taxation of nonresidents not citizens (Chapter 11, Subchapter B, sections 2101-2108). This chart is designed for students, professionals and experienced scholars alike – anyone who needs a...

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...

In this Special Report for Tax Notes, the authors explain the variety of income and gift tax deductions, credits and exclusions for higher education, and the tax consequences of educational debt relief programs. They recommend steps the federal government could take to make higher education more...

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...

This Article considers important consequences of the commodification of human reproduction. Anyone who has opened a campus newspaper has seen advertisements seeking to match an infertile couple with a young woman who will “donate” her egg (in return for a fee). Some college-age men earn...

This article provides an overview of the U.S. estate tax rules that apply to nonresidents who are not U.S.citizens. The long arm of the U.S. federal estate tax extends to individuals who have assets located in the United States even if the individual is neither a resident nor a citizen of the...

In this article, Professor Crawford proposes limiting the gift tax annual exclusion to outright transfers and transfers in trust that will be included in the beneficiary’s gross estate. The proposal is made as a part of the Shelf Project, a collaboration among tax professionals to develop...

At the end of 2010, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 was enacted to extend many of the Bush-era tax cuts. It also increased the estate and gift tax exemption to $5 million, lowered the rate to 35% and implemented spousal portability for...

This article addresses the specific question of who -- as between the beneficiaries of the estate and the lifetime donees -- will bear responsibility for estate tax generated with respect to gift tax included in the decedent’s gross estate, absent a specific provision to the contrary. Although...