Each taxpayer is allowed - for federal gift, estate, and Generation Skipping Tax purposes - an exemption of $5,490,000 (for 20017 - the amount adjusts annually). For decedents' estates who do not take full advantage of the exemption, the IRS Code allows - for gift and estate tax, but not for Generation Skipping Tax - any unused exemption to be "ported" to the decedent's surviving spouse. This "portability" must be elected by the estate of the first spouse to die on a timely

It is widely known that many states do not impose estate tax. Here in the Northeast, it is common to hear someone say that she is a Florida resident, and thus (i) pays no income tax and (ii) will avoid state estate tax. True enough, if actually a resident and domiciliary. Residence for income tax purposes and for estate tax purposes are based on separate factual considerations. Income tax residence tends to be based on facts (e.g., number of days in a state) while a person'

The Generation Skipping Transfer Tax was instituted in 1986. Events and Transfers subject to this tax occur in various situations. And when they occur (even if there is no tax due) GSTT tax returns are required. Worse, if there is tax, the trustee may have personal liability for unpaid tax. It is now 2017 - the tax has been in effect for 31 years (well, with one year off in 2010!). So-called "taxable events," which require reporting, are starting to occur, and frequency will