Federal Wealth Transfer Taxation (University Casebook Series): Cases and Materials by Paul R. McDaniel, Paul L. Caron, James R. Repetti, James R. Repetti, Paul L. Caron

Part I: Overview of the Federal Wealth Transfer Tax System

Chapter

An Historical Review

Data on U.S. Wealth and Wealth Transfer Taxes

Policy Aspects of a Wealth Transfer Tax

A Brief Summary of Transfer Tax Procedure

Basic Application of the Transfer Taxes

Coordinating the Computation of the Estate and Gift Taxes

Constitutional Aspects of Transfer Taxes

The Role of State Law

Part II: Composition of the Tax Base: General Principles

The scope of the Estate Tax Sec. 2003

The Scope of the Gift Tax: Sec. 2501 and 2511

Part III: Composition of the Tax Base: Specific Transfers

Transfers of Property in Satisfaction of Marital Rights

Transfers with Retained Powers and Rights

Transfers with Retained Powers to Alter, Amend, Revoke, or Terminate: Sec. 2038

Transfers with Retained Reversionary Interests Sec. 2037

The “Adequate and Full Consideration” Exception

Gift Tax Effects of Transfers with Retained Interests or Powers

Annuities and Employee Benefits

Joint Interests in Property

Powers of Appointment

Life Insurance

Transfers Made within Three Years of Death

Disclaimers

Part IV: Exclusions, Deductions, and Credits Necessary to Define the Tax Base

The Gift Tax annual Exclusion: Resolution of Administrative Problems of Taxing Small Transfers

Estate Tax Deductions Necessary to Define the Net Transfer

The Unified Transfer Tax Credit

Part V: Other Deductions and Credits

The Deduction for Charitable Contributions

Other Tax Credits

Tax Expenditures in the Wealth Transfer Taxes

Part VI: The Taxable Unit

The Marital Deduction

Part VII: The Taxation of Transfers from Generation to Generation

The Generation-Skipping Tax

Part VIII: Valuation

Time of Valuation

Valuation Methods

Impact of Buy-Sell Agreements, Lapsing Rights, and Liquidation Restrictions on Valuation

Estate Freezes

Part IX: Administrative Aspects of Wealth Transfer Taxes

Tax Responsibilities of the Executor

Part X: International Aspects of Wealth Transfer Taxation

U.S. Jurisdictional Principles

The Foreign Tax Credit

Transfers to a Non-Citizen Spouse

Transfers by Non-Resident Aliens

Wealth Transfer Tax Treaties