In light of the fact that we currently are burdened with a Congress so entrenched in party politics that it was almost willing to do nothing when the debt ceiling crisis arose last year, it may be a good time to examine another area of the law in which reliance upon statutes, or a simple ignorance of the law, has seemingly dominated the manner in which many attorneys practice: the generation-skipping transfer tax, or GSTT.

This problem stems in large part from provisions implemented as part of the Economic Growth and Tax Relief Reconciliation Act of 2001, or EGTRRA, and could come back to bite many a practitioner during the next few years.