All generation-skipping transfers
are taxed at the "applicable rate" (a flat rate equal to the maximum federal estate tax rate in effect at the time of the generation-skipping transfer
) multiplied by the "inclusion ratio.
Generally, a tax is imposed on generation-skipping transfers
(GST) of property, which includes a taxable distribution, a taxable termination, and a direct skip.
(Q 951) include direct skips, taxable terminations, and taxable distributions.
(Q 1510) include direct skips, taxable terminations, and taxable distributions.
This chapter discusses the generation-skipping transfer
tax and planning with generation-skipping transfers
, including the use of generation-skipping trusts.
1 million in generation-skipping transfers
(transfers to skip persons) without paying the GST tax.
The GST tax currently is not applicable to generation-skipping transfers
made during 2010, so the following discussion is pertinent to gifts made in 2009.
Few existing recordkeeping systems at CPA firms are able to sort clients by age, net worth, number of dependents, annual gifts, gift tax returns, generation-skipping transfers
, family foundations or other tax- or investment-related issues that might require a CPA firm to send a reminder.
The GST subjects generation-skipping transfers
to an additional tax that approximates the gift or estate tax that would have been due had a generation not been skipped.
Primary among the new legislation are the changes to the transfer tax system, which will ease administration of the laws that govern estates, gifts and generation-skipping transfers
2503(e) and were not generation-skipping transfers
2503(e) and will not be deemed generation-skipping transfers
(GSTs) under Sec.