The “permanence” of the $5.25 million inflation-indexed applicable exclusion amount in the American Taxpayer Relief Act of 2012 (ATRA) gives estate-planning and investment professionals the opportunity to re-examine how they advise clients. For many, tax-driven planning will take a back seat—supplanted, perhaps, by non-quantitative considerations. But, there are some situations in which rigorous quantitative analysis is more important than ever. Prior to ATRA, many ...

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