The tenuousness of the President’s plan raises a whole host of additional questions. These include: (1) whether the President’s plan would be coupled with a step-up in basis at death versus carryover basis (carryover basis would effectively increase total taxes for most married couples with under $11 million in total wealth), (2) whether the gift tax will remain intact (presumably it’s needed to prevent a massive erosion of the income tax base) and (3) what will happen to the generation-skipping transfer tax.
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