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GENERATION SKIPPING TRANSFERS i (MEMORANDUM 2, September 15, 1983)

handle is hein.ali/aliestate0034 and id is 1 raw text is: THIS DRAFT IS PRIVATE AND CONFIDENTIAL PUBLIC DISCLOSURE IS PROHIBITED* (Not to be sold, offered for sale, or othertvise published) The American Law Institute FEDERAL ESTATE AND GIFT TAX PROJECT STUDY ON GENERATION-SKIPPING TRANSFERS UNDER THE FEDERAL ESTATE TAX Memorandum No. 2 Subjects Covered: Alternative I - A Tax on Skipping Tranrfers I. Taxation of Skipping Transfers A. General Rule I - Trusts Treated as Owned by Beneficiary B. General Rule II - Trusts Not Treated as Owned by Beneficiary C. General Rule III - Deduction for Transfers to Children of Grantor D. A Note on the Amount of the Taxable Transfer and Its Relationship to Trust Income Alternative II - The 1983 Treasury Department Generation-Skipping Tax Proposal Submitted to the Consultants for consideration at their meeting on October 2 (at 9:00 a.m.) and 3, 1983, at The Colonial Williamsburg Foundation, Williamsburg, Virginia September 15, 1983 The Executive Office THE AMERICAN LAW INSTITUTE 4025 Chestnut Street Philadelphia, PA 19104 'This is a preliminary draft submitted on a private and confidential basis to a limited group for the sole purpose of study and criticism. It has not been promulgated or approved by the Council or the members of The American Law Institute. As an unpublished document intended for internal use, this draft should not be generally circulated or distributed, nor should it be quoted from or cited or its substance disclosed in any public address or writing.

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