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The wide-ranging changes to U.S. tax law contained in the Tax Cuts and Jobs Act of 2017 (P.L. 115-97, the act) have created opportunities for clients whose net worth is expected to remain below the federal estate and gift tax exemption amounts.  In particular, practitioners may wish to analyze the federal generation-skipping transfer tax (GST) treatment of existing irrevocable trusts in order to confirm each trust’s inclusion ratio and, if appropriate, take affirmative steps to allocate GST exemption to partially exempt trusts.

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