Taxing Income and Appreciation in a Generation Skip

Abstract

<p>The repeal of the generation-skipping transfer tax in 2001<strong>1 </strong>effective after December 31, 2009,<strong>2 </strong>but with the repeal not applicable after December 31, 2010,<strong>3 </strong>was confusing in itself but the re-enactment of the generation-skipping transfer tax in 2010<strong>4 </strong>retroactive to January 1, 2010<strong>5 </strong>has added to the confusion and raised questions about the tax treatment of distributions after 2010 for both income and principal in a generation-skipping transfer set up in 2010.<strong>6 </strong>Questions have been raised, also, about the handling of undistributed income in a generation skip before 2010 and after 2010.</p>