Wednesday, March 24, 2010
- Adding a required ten-year minimum term on the right to receive fixed payments.
- Requiring that payments can not decrease relative to any prior year during the first 10 years of the term.
- Requiring that the remainder interest have a value greater than zero, determined at the time of the transfer.
See H.R. 4849; see also Hani Sarji, H.R. 4849 would revise Sec. 2702 rules regarding GRATs, Future of the Federal Estate Tax, March 19, 2010.
Special thanks to Hani Sarji (LL.M in Tax candidate at New York Law School) for bringing this to my attention.