The passage of the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 (the 2010 Tax Relief Act) has opened an unexpected window of opportunity for the tax-exempt transfer of significantly more wealth to the next generation than was possible under prior regulations. The unification of the gift and estate tax exemptions at $5 million, allowing individuals to give up to $5 million tax-free during their life or at death, combined with lowering the tax rate on taxable ...

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