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On May 28, President Biden and his administration released its revenue-raising proposals in the Treasury Department’s General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (the Green Book).1 For estate planners, the proposals were interesting both for what was included and what wasn’t. Most notably, the much anticipated reduction in the estate and gift tax exemption didn’t make it into the Green Book nor did any changes to the transfer-tax regime. Instead, the Biden administration is proposing to make death, lifetime giving and exceeding maximum holding periods for assets in trust recognition events for income tax purposes. If this proposal comes to fruition, gifts and bequests would be subject to not just one t...
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