Every indexed document

we expect to issue a more detailed Tax Alert.

independent of whether the federal estate tax is repealed.

Proposed Regulations May Limit/Eliminate Valuation Discounts for Family Controlled

we have highlighted some of the tax proposals

will play an enhanced role. If federal estate tax repeal is only temporary

it will obviously depend on what changes are enacted. If the estate tax is repealed

it may be advisable to include flexible provisions

such gifts may still be beneficial. Even if the gift tax were repealed

then such gifts may continue to be advisable.

unless there is an applicable state estate tax 4 . However

that would not be true if the estate tax is repealed.

there are some general guidelines to consider.

with the uncertain future consequences of

we believe it is likely the IRS will not proceed with these regulations. For now

there was a temporary repeal of the estate tax (and other taxes)

however specific details have not been offered. The proposal sets forth a $10 million

repealing the estate tax would not suggest that the gift tax

repealing the estate tax would suggest that the gift tax would also be repealed.

the federal tax rate is 40%. If an appreciated asset is includible in the estate

the federal exemption for estate and gift tax is $5 million