Reprieve From Unbundling
The introduction to the article and the April 2010 edition of The Estate Analyst is below:
Ironic twists that impact estate planning were contemplated as an initial organizing principle for this collection of recent developments.
However, the rich veins of irony that run through the subject matter of taxation are so bountiful that merely scratching at the surface soon yields gushers of irony. Cases redolent in irony. Issues saturated in irony. A legislature that is never shamed by the tsunami of irony it produces.
Oh, the irony!
We have therefore limited these selections to just a few areas. The same Congress which forgot to stop the estate tax from being repealed entirely (oops) and which has failed to reimpose it at 2009 rates retroactively for four months and counting (whoops) has ironically set in motion a stringent limitation on a popular wealth transfer technique, the Grantor Retained Annuity Trust (GRAT).
Not to be outdone, the IRS, which has tried to unbundle investment fees but hasn’t come up with a viable means of doing so, has now, ironically enough, postponed its own edict for the third successive year.
And Eyjafjallajökull isn’t just a catchy name for a volcano. It is a metaphor, an analogy, and a device to report on the latest estate tax un-repeal developments. There is sure to be an ironic element in that mix upon closer inspection.