Lawyers Ask Treasury to Set Two-Generation Limit on GST Exemption
Published: August 17, 2010
AALU has learned that at least four attorneys in academia and private practice have written to the Treasury Department asking that a durational limit – suggested to be two generations – be placed on trusts that qualify for the generation-skipping transfer (GST) tax exemption, thus eliminating the incentive to establish so-called “perpetual dynasty trusts” in jurisdictions that have abolished the common law “rule against perpetuities.” The Treasury correspondence was submitted by Gregory S. Alexander of Cornell University Law School, Raymond H. Young of Young & Bayle (a Boston law firm), John H. Langbein of Yale Law School, and Lawrence W. Waggoner of the University of Michigan Law School.
