Taxing Income and Appreciation in a Generation Skip

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2011-04-15
Authors
Harl, Neil
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Abstract

The repeal of the generation-skipping transfer tax in 20011 effective after December 31, 2009,2 but with the repeal not applicable after December 31, 2010,3 was confusing in itself but the re-enactment of the generation-skipping transfer tax in 20104 retroactive to January 1, 20105 has added to the confusion and raised questions about the tax treatment of distributions after 2010 for both income and principal in a generation-skipping transfer set up in 2010.6 Questions have been raised, also, about the handling of undistributed income in a generation skip before 2010 and after 2010.

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