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The allocation of GST exemption to a transfer or to a trust excludes from the GST tax not only the amount of the transfer or trust assets equal to the amount of GST exemption allocated, but also all appreciation and income on that amount during the existence of the trust.
FORBES: Obama Estate Tax Budget Proposals
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If the will, in contrast, says that the trust is funded up to the amount of whatever federal estate exemption is in effect on the date of your death, it could get too much.
FORBES: Death, Taxes and Dice Rolling
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Irrevocable trusts enable individuals to avoid estate tax on more than the exemption equivalent amount of property.
FORBES: Estate Planning Overview and Objectives
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We'd still say the exemption provides some small amount of relief for Samsung, however.
ENGADGET: Judge cuts international Galaxy S and S II, Galaxy Ace from Apple lawsuit against Samsung
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On the death of the first, the exemption amount goes into a "bypass" trust for the kids, with the rest going to the surviving spouse.
FORBES: Estate planning
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At the death of the first spouse a chunk of his or her assets--equal to the exemption amount--would go into a "bypass" or "credit shelter" trust, with the rest going directly to the surviving spouse, who can inherit an unlimited amount free of estate tax.
FORBES: Before It's Too Late
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Dynasty trusts push that generation-skipping tax exemption to the max, putting the exempted amount beyond the reach of estate taxes for the life of the trust.
WSJ: Tax Report: Dynasty Trusts Under Attack
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Such a low exemption amount will make it more difficult for families to accumulate wealth and retain assets for the benefit of their children and descendents.
FORBES: 2012 Tax Legislation: Obama likely to Cut Taxes ... For the Rich