IRSThe United States Department of the Treasury will not do much in 2014, what with it being an election year and all. The year 2015, however, is a different story.  It is not too early to make some reasonable guesses as to what estates and estate planners can look forward to.  In fact, the 2014 General Explanations of the Administration's Fiscal Year 2014 (the Green Book) proposals that pertain to estate planning offer a view of what could potentially happen in 2015. Here are some bullets on a few of the key provisions of the Green Book proposals.


  • The estate, gift and generation-skipping transfer (GST) tax exclusions and rates may revert back to 2009 rules.  Among other things, under this proposal, the estate and GST tax exemption amounts would be reduced to $3.5 million, while the gift tax exemption would be reduced to $1 million.
  • Sales, exchanges and “comparable transactions” with grantor trusts may change. Chief among the changes may be, once again, an attempt by he Obama Administration to resolve the disconnect between the income tax rules and the estate tax rules that apply to intentionally defective grantor trusts (IDGTs).
  • Additional restrictions may be put on grantor retained annuity trusts.  Much of this proposal would greatly diminish the attractiveness of grantor retained annuity trusts (GRATs) by, among other things, requiring a minimum term of 10 years, which prevents the front-loading of the GRAT annuity and imposing a minimum taxable gift requirement.

  • There may be additional Green Book proposals pertaining generally to estate planning, qualified plans and individual retierement accounts, including but not limited to:

    • A change to existing law under IRC Section 101 that subjects “buyers of policies” to the “transfer-for-value” exception to the exclusion of life insurance proceeds for income tax purposes.
    • A limit on the scope of the current law exclusion under IRC Section 2611(b)(1).  The exclusion would only apply to payments made by a living donor directly to the provider of medical care or to the school for tuition.
    • A consistency requirement will be imposed for basis purposes between what’s reported as fair market value on the decedent’s Form 706 Federal Estate and Generation-Skipping Transfer Tax Return and what the beneficiary later reports as his stepped-up basis on the decedent’s death for income tax purposes.
    • Under IRC Section 6324(a)(1), there is a proposal for an extension of the 10-year estate tax lien  to cover the entire 14 year and nine month term subsequent to the decedent’s death that’s subject to the deferral of estate tax under IRC Section 6166.

For more, read this fairly detailed article written by Ken Matz on  It fleshes out our outline with more detail.  

It is not too soon to plan for 2015.  If you have questions, contact us and ask for our Estate Planning Team. We would love to help you.


- The Estate Planning Team
  Rogers Sheffield & Campbell, LLP

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