Allocating GST Exemption to GRAT Property After the Annuity Term

This Article surveys questions regarding the allocation of GST exemption to GRAT property. Official guidance on these questions is at best unsatisfying, and there is little consensus, or in some cases even engagement, among commentators. Confidence in one’s answers can be atypically important because legal “finality” is often many years away. The Article concludes with tactical suggestions for increasing certainty.