In Part I of this article,1 we discussed the increased significance of the income tax consequences of estate planning in light of the American Taxpayer Relief Act of 20122 and the 3.8 percent tax on net investment income3 and highlighted the effect that a narrowing tax efficiency gap4 and a “permanent”$5 million estate tax exemption, indexed for inflation($5.344 million for 2014), have had on the tax efficiency of lifetime gifts. We now turn to the various post-gift ...

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