Planning with Portability Do-Overs (But Only for a Limited Time)

5 Pages Posted: 15 Apr 2014 Last revised: 22 Apr 2014

See all articles by Bridget J. Crawford

Bridget J. Crawford

Pace University School of Law

Jonathan G. Blattmachr

Milbank, Tweed, Hadley & McCloy LLP

Date Written: April 7, 2014

Abstract

In this article, the authors discuss Rev. Proc. 2014-18, in which the IRS provides some estates with a simplified method for making a portability election and having that election treated as timely even though the statutory deadline may have passed. The authors suggest that once the estate tax exemption of a first spouse to die has been preserved under Rev. Proc. 2014-18, an effective estate plan for the surviving spouse may include creating and funding a lifetime trust structured as a grantor trust.

Keywords: estate tax, portability, election, tax, Revenue Procedure

JEL Classification: K34, K19

Suggested Citation

Crawford, Bridget J. and Blattmachr, Jonathan G., Planning with Portability Do-Overs (But Only for a Limited Time) (April 7, 2014). Tax Notes, Vol. 143, No. 1, 2104, Available at SSRN: https://ssrn.com/abstract=2422400

Bridget J. Crawford (Contact Author)

Pace University School of Law ( email )

78 North Broadway
White Plains, NY 10603
United States

Jonathan G. Blattmachr

Milbank, Tweed, Hadley & McCloy LLP ( email )

1 Chase Manhattan Plaza
New York, NY 10005
United States
212-530-5066 (Phone)

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