On Dec. 17, 2010, in a surprising last-minute move, President Barack Obama signed into law the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010. The Department of the Treasury also has released its General Explanations of the Administration’s Fiscal Year 2012 Revenue Proposals (the 2012 revenue document). Reading the two creates a number of action items for lawyers to discuss with their high net-worth clients.

The 2010 tax act clarified, at least temporarily, much of the uncertainty that existed because of Congress’ failure to enact permanent legislation — if such a thing exists — with respect to the federal transfer tax regime for 2010.