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Generation-Skipping Transfer Tax and Post-Mortem Planning: Tax Rules, Allocations, Formula Drafting, Key Challenges

Recording of a 90-minute CLE/CPE video webinar with Q&A

This program is included with the Strafford CLE Pass. Click for more information.
This program is included with the Strafford CPE+ Pass. Click for more information.
This program is included with the Strafford All-Access Pass. Click for more information.

Conducted on Thursday, November 30, 2023

Recorded event now available

or call 1-800-926-7926

This CLE/CPE course will provide estate planners guidance on key generation-skipping transfer (GST) tax planning techniques under current tax law. The panel will discuss applicable GST rules and utilizing those rules to the advantage of clients, allocations, formula drafting, and more. The panel will also discuss reporting requirements, computing the GST tax, key challenges, and pitfalls to avoid.


A solid foundation in the GST tax regime of Section 2632 and following statutes is critical to successful multi-generational gift tax planning and compliance. Estate planners must grasp skip-person transferees and gifts that will trigger GST tax, the "inclusion ratio" rules to calculate the tax cost of GSTs, and formula drafting.

Estate planners should utilize all available mechanisms, such as gifting, trusts, and other transfer methods. GST tax planning can assist in limiting or avoiding gift and estate taxes. Reducing the estate and gift tax exemption will impact taxpayers wishing to leave substantial amounts to grandchildren or trusts that will eventually pass to grandchildren.

The amount of the exemption from the federal GST tax is currently equal and tied to the amount of the estate and gift tax exemption. Therefore, any reduction in the estate and gift tax exemption will likewise reduce the GST tax exemption. Section 2642 provides the framework for determining the taxable portion of any GST under GST tax.

Furthermore, special rules apply to inclusion ratios and applicable fraction formulas, depending on the type of trust receiving a GST. To avoid costly tax consequences, estate planning counsel and advisers need to be constantly aware of the impact of these rules on transfers subject to the GST rules.

Listen as our experienced panel provides a deep and practical guide to applicable GST rules and methods for utilizing those rules to the advantage of clients, allocations, formula drafting, and more.



  1. GST transfer tax and allocations
  2. GST severance rules and late allocation rules
  3. IRC 2642 structure
  4. Calculation of inclusion ratio
  5. Planning implication of pre-transfer inclusion ratio and fraction calculations
  6. Trusts; preserving asset basis and other tax attributes


The panel will review these and other important topics:

  • How can GST tax planning assist clients under current tax law and in anticipation of tax law changes?
  • How do you spot trusts with an inclusion ratio greater than zero?
  • What is the interrelation between the inclusion ratio and an applicable fraction under Section 2642 and its regulations?
  • How can trust division or modifications be used to preserve asset basis?


Mendel, Jennifer
Jennifer A. Mendel

Barnes & Thornburg

Ms. Mendel has spent the last 15 years honing her craft counseling high net worth families on complex trust, estate and...  |  Read More

Rappaport, Matthew
Matthew E. Rappaport, Esq., LL.M.

Vice Managing Partner
Falcon Rappaport & Berkman

Mr. Rappaport counsels clients on technical and complex tax issues. He works closely with closely held business owners,...  |  Read More

Access Anytime, Anywhere

Strafford will process CLE credit for one person on each recording. CPE credit is not available on recordings. All formats include course handouts.

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