1 Since gift tax may have been paid when the GRAT was established (or a substantial amount of the lifetime gift exemption was used), the amount of the tax paid is credited against estate tax payable
Prior to EGTRRA, Florida imposed a "pick-up estate tax," such that the estate tax payable
to Florida was equal to the state death tax credit.
If the parents simply gave or transferred the family wealth on death to their US-resident children, there would be estate tax payable
when the children die.
6166 2% interest rate for the applicable portion of the estate tax payable
in installments increased to $1.
Section 6601(j) provides for a four-percent interest rate on certain estate tax payable
in installments pursuant to section 6166, in lieu of the rate set under section 6621.
6166 tax deferral for closely held businesses: The 2% interest rate for the applicable portion of the estate tax payable
in installments is increased to $1,030,000 for 2000.
37] It may be impossible to meet this requirement if a testamentary document includes an optimum marital deduction formula that automatically results in zero estate tax payable
6166 two-percent interest rate for the applicable portion of the estate tax payable
in installments is increased to $1.
and] shall cause there to be the smallest possible (or no) Federal estate tax payable
by my estate taking into account all available credits .
The IRS has ruled that no marital deduction adjustment need be made in determining the estate tax payable
when the value of the transferred property is excluded from the decedent's estate.
The IRS previously held that post-death interest accruing on deferred Federal estate tax payable
from a testamentary transfer reduces the date-of-death value of that transfer.
The "second limitation" equals the difference in the estate tax payable
before the credit and the estate tax payable
if the net value of the transferred property is excluded from the transferee's gross estate.