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Capital Letters

Ronald D. Aucutt

Beth Shapiro Kaufman

ACTEC Past President Ronald (Ron) D. Aucutt (2003–2004) has authored Capital Letters since 2006, offering his insight into the legislative process behind estate tax reform, related transfer tax deliberations of the U.S. Congress, and administrative developments at the Treasury and IRS.

Capital Letter No. 62, published on October 4, 2024, marks Ron’s final contribution to the series. Beth Shapiro Kaufman, who co-authored Capital Letter No. 62, will take over the authorship of future installments.

The College thanks Ron for sharing his expertise and insights through Capital Letters over the past 18 years and welcomes Beth as she continues this important tradition. A Preface by both authors is found in Capital Letter No. 62.

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Capital Letter No. 62 - Final Basis Consistency Regulations, Like Earlier GST Election Regulations, Are Very Responsive to Public Comments

Post date October 4, 2024
Categories Capital Letters

By Ronald D. Aucutt and Beth Shapiro Kaufman

The final basis consistency regulations, released September 16, 2024, show significant improvements over the proposed regulations and continue to illustrate the seriousness with which Treasury and the IRS view comments from the public.

Capital Letter No. 61 - Reimbursement of Grantor for Income Tax Paid on a Grantor Trust’s Income

Post date January 19, 2024
Categories Capital Letters

Ronald D. Aucutt

The IRS rules, questionably, that trust beneficiaries have made a taxable gift by consenting to add to the terms of a grantor trust a discretionary power in the independent trustee to reimburse the grantor for income tax the grantor pays on the trust’s income.

Capital Letter No. 60 - Selected Income, GST, Gift, and Estate Tax Proposals in the Greenbook

Post date March 30, 2023
Categories Capital Letters

Ronald D. Aucutt

The Fiscal Year 2024 Greenbook includes many income, GST, estate, and gift tax proposals, including recognition of gain on gifts, transfers at death, and sales between a grantor trust and the deemed owner, and limitations on the GST exemption, GRATs and CLATs, the annual gift tax exclusion, and private operating foundations.

Capital Letter No. 59 - Valuation in Treasury’s Greenbook

Post date March 21, 2023
Categories Capital Letters

Ronald D. Aucutt

The Fiscal Year 2024 Greenbook includes significant proposals to change estate and gift tax valuations.

Capital Letter No. 58 - The Top Ten Estate Planning and Estate Tax Developments of 2022

Post date January 23, 2023
Categories Capital Letters

Ronald D. Aucutt

Developments in 2022 addressed valuation tools and rules (for valuing both assets and deductions), retirement plan distributions, IRS funding, IRS rulemaking, arbitration, gifts with retained benefit or control, flexible charitable remainder trusts, and split-dollar life insurance.

Capital Letter No. 57 - A Surge of Administrative Guidance

Post date August 11, 2022
Categories Capital Letters

Ronald D. Aucutt

In the last four months, administrative guidance
has addressed four significant topics.

Capital Letter No. 56 - The Administration’s Fiscal Year 2023 Budget Proposals

Post date April 21, 2022
Categories Capital Letters

Ronald D. Aucutt

The Treasury Department’s General Explanations of the Administration’s Fiscal Year 2023 Revenue Proposals offers a few new ideas and a lot of refining and refocusing of ideas previously offered.

Capital Letter No. 55 - Top Ten Estate Planning and Estate Tax Developments of 2021

Post date January 12, 2022
Categories Capital Letters

Ronald D. Aucutt

2021 “top ten” developments includes discussions of the significance of the continuing Covid challenge, and more.

Capital Letter No. 54 - 2021-2022 Treasury – IRS Priority Guidance Plan

Post date October 19, 2021
Categories Capital Letters

Ronald D. Aucutt

Amidst the current whirlwind of uncertainty about pending legislation, let’s pause to be reminded of the projects in the somewhat more predictable Treasury – IRS Priority Guidance Plan.

Capital Letter No. 53 - Ways and Means Committee’s ” Build Back Better Act “

Post date October 18, 2021
Categories Capital Letters

Ronald D. Aucutt

The House Ways and Means Committee has taken a widely discussed (and in many respects exasperating) step to foretell the tax legislation we might see this year.