The Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 (2010 Act) created a major change that came as a surprise to many observers: the “reunification” of the federal gift and estate tax systems. Since 2002, the gift and estate tax exemption amounts had been “decoupled.” This meant, for example, that in 2009, the $1 million an individual could give to others free of tax during his lifetime was significantly less than the $3.5 million ...

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