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Estate & Gift Taxation — Overview

Death is not an inexpensive proposition. Besides the expenses associated with transferring property to heirs, the federal and state governments impose death taxes. For many estateholders, the death tax bill will be the single largest tax ever paid — unlike income taxes that periodically tax the creation of wealth, death taxes impose a levy against the total, lifetime accumulation of wealth.

Three Types of Transfer Tax

Estate Tax
A levy on the amount of property in the estate. The executor pays from estate assets before distribution to heirs. Imposed by the federal government and some states.
Inheritance Tax
A levy on the amount received by each beneficiary. The beneficiary is typically responsible for payment. No federal inheritance tax — some states impose one.
Gift Tax
A levy on transfers of property during the donor’s lifetime. The federal gift tax is unified with the estate tax. Only Connecticut currently imposes a state-level gift tax.
State gift taxes: At one time, several states imposed gift taxes. Louisiana repealed its gift tax in 2007, North Carolina in 2008, and Tennessee in 2012. Connecticut is now the only state with a standalone gift tax, and it has been progressively unified with its estate tax.

Other Tax Consequences of Estate Planning

In addition to transfer taxes, the estate planner must also consider other tax consequences of the estate plan. For example:

A lifetime gift of appreciated stock shifts the income tax on future dividends and capital gains to the recipient. Any appreciation in the shares after the gift becomes a taxable gain to the donee, not the donor. The donee also takes the donor’s original cost basis — meaning a large embedded gain may be inherited along with the asset.

By contrast, assets held until death generally receive a step-up in basis to their fair market value at the date of death, potentially eliminating the capital gain entirely for the heirs. This income tax advantage of holding appreciated assets until death must be weighed against the potential estate tax cost of keeping them in the taxable estate.

This program concentrates primarily on the transfer tax aspects of the planning process, but will note significant income tax considerations where they arise. The following pages cover the federal gift tax, the federal estate tax, the generation-skipping transfer tax, and state-level transfer taxes.

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