| Definition: | This is a tax on estate tax transfers, generally through trusts that are intended to avoid estate taxes. There is a $1 million exemption, but the taxpayer has to elect to allocate it to a transfer, and this is hard to do when it is uncertain what the future value of the transfer will be. The result has been liability for practitioners for failing to elect to allocate some of the exemption to the transfer. This is a major issue currently for the big five, which have millions in potential liability.
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