The Dec. 17, 2010 enactment of the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010 (2010 Tax Act) added the concept of portability and dramatically increased the gift tax exemption to $5 million per individual ($10 million for married couples). (See “New Rates, New Exemptions, New Gifting Opportunities,” by Douglas Moore and David A. Handler in the February 2011 issue of Trusts & Estates, p. 20.) For wealthy clients, the combination of
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