Article on Exploiting DSUE Portability

Robert L. Moshman (Attorney, New York and New Jersey) recently published his article entitled, Exploiting DSUE Portability, The Estate Analyst (Feb. 2014). An excerpt from the article is below:

Should a portability election be filed for the estate of every first spouse to die? What if the joint marital estates are relatively small? Is there a downside to overreliance on portability? Let’s consider how the deceased spouse’s unused exemption (DSUE) impacts planning in several different scenarios and consider the latest IRS guidance on extensions for filing the election from Revenue Procedure 2014-18.