The 2012 American Taxpayer Relief Act has greatly changed the engineering of estate plans. Now, with a $5.34 million (in 2014) exclusion amount indexed for inflation, lower estate tax rates, higher capital gains rates and Internal Revenue Code Section 2010(c) (that is, portability), practitioners are often designing flexible plans to maximize step-up in basis. For some couples, the new law may greatly simplify their planning, but for others, options abound, resulting in greater complexity. ...

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