The standard chunk of Lorem Ipsum used since the 1500s is reproduced below for those interested. Sections 1.10.32 and 1.10.33 from “de Finibus Bonorum et Malorum” by Cicero are also reproduced in their exact original form, accompanied by English versions from the 1914 translation by H. Rackham.
There are many variations of passages of Lorem Ipsum available, but the majority have suffered alteration in some form, by injected humour, or randomised words which don’t look even slightly believable. If you are going to use a passage of Lorem Ipsum, you need to be sure there isn’t anything embarrassing hidden in the middle of text. All the Lorem Ipsum generators on the Internet tend to repeat predefined chunks as necessary, making this the first true generator on the Internet. It uses a dictionary of over 200 Latin words, combined with a handful of model sentence structures, to generate Lorem Ipsum which looks reasonable. The generated Lorem Ipsum is therefore always free from repetition, injected humour, or non-characteristic words etc.

The following is a summary of the key components of the estate and gift tax implications of this new law, which are applicable for 2011 and 2012 only:

 1.         Estate Tax Issues:

• The Estate Tax Exemption and Rate:  Estates in excess of $5 million (per individual and indexed for inflation starting 2012) will be subject to a top estate tax rate of 35 percent.
•  Portability of Estate Tax Exemption:  The general rule is that, starting in 2011, any unused estate tax exemption of a decedent may be applied to the surviving spouse’s estate to be used upon the surviving spouse’s death.  The portability of the exemption requires that an election be made on the deceased spouse’s estate tax return and, as with most new laws, is subject to numerous exceptions and ambiguities.  It is important to recognize that this portability only applies to deaths that occur after 2010.

 2.         Gift and Generation Skipping Transfer (GST) Tax Issues:

•  The Gift Tax and GST Tax Exemption and Rate: The gift tax rate and GST tax rate for 2011 and 2012 will remain at 35 percent with a new lifetime gift tax exemption of $5 million and GST tax exemption of $5 million (both adjusted for inflation starting in 2012).
•  Portability of the Gift Tax Exemption:  Starting in 2011, surviving spouses may apply any unused exemption from their last deceased spouse to gifts made during their lifetime. Again, this portability only applies to deaths that occur after 2010 and does not apply to the GST tax exemption. 

 The most significant advantage of these new laws is the temporary increase in the lifetime gift exemption and GST exemption to $5 million (or $10 million for a married couple).  Clients should consider taking advantage of the increased exemptions and lower tax rates before 2013 when these new laws will expire. 

A practical concern raised by these new provisions is that clients may be lulled into complacency due to the size and portability of the current tax exemptions. It is important to recognize that simple portability does not provide the advantages of estate planning structures that are specifically designed to take advantage of the estate tax exemption and future appreciation of assets placed in a trust created to maximize the benefit of the estate tax exemption.  Failure to create an estate plan that utilizes the remaining exemption in the most tax efficient manner could be very costly for a decedent’s family.