The imbalance between the assets in generation-skipping transfer (GST) tax-exempt and GST tax-vulnerable trusts continues to grow. The much larger estate and gift tax exclusion and GST tax exemption amounts available to taxpayers since the enactment of the 2017 Tax Cut and Jobs Act of 2017 (TCJA) haven’t slowed the increase of overfunded GST tax-vulnerable trusts. Whether the TCJA’s transfer tax provisions expire as scheduled on Jan. 1, 2026, the number of large GST tax-vulnerable trusts is
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