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ACTEC Comments Concerning Expatriation Legislation

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Daniel H. Markstein, III
Maynard, Cooper Gale, P.C.
1901 6th Avenue North
2400 AmSouth/Harbert Plaza
Birmingham, Alabama 35203-2602
Direct Dial: (205) 254-1043
E-mail: dmarkstein@maynardcooper.com
December 7, 2007
Honorable Max Baucus
Chairman
Committee on Finance
U.S. Senate
219 Dirksen Building
Washington, DC 20510
max_baucus@baucus.senate.gov
Honorable Charles Grassley
Ranking Member
Committee on Finance
U.S. Senate
219 Dirksen Building
Washington, DC 20510
chuck_grassley@grassley.senate.gov
Honorable Charles B. Range1
Chairman
Committee on Ways and Means
U.S. House of Representatives
1102 Longworth House Office Building
Washington, DC 20515
rangel@mail.house.gov
Honorable Jim McCrery
Ranking Member
Committee on Ways and Means
U.S. House of Representatives
1102 Longworth House Office Building
Washington, DC 20515
jim.mccrery@mail.house.gov
Re: Expatriation Legislation
Dear Chairman Baucus, Chairman Rangel, Senator Grassley, Representative McCrery:
I write you in my capacity as president of the American College of Trust and Estate Counsel ("ACTEC"). ACTEC is a professional association of approximately 2,600 lawyers hm bugtrout the United States. Fellows of the College are elected to membership by their peers on the basis of professional reputation and ability in the fields of trusts and estates and on the basis of having made substantial contributions to these fields through lecturing, writing, teaching, and bar activities. ACTEC offers technical comments about the law and its effective administration. It does not take positions on matters of tax policy.

On October 10,2007, comments on expatriation legislation proposals were submitted by Ellen K. Harrison. She, Henry Christensen, III, Virginia F. Coleman, Robert C. Lawrence, III, Carlyn S. McCaffrey, Gideon Rothschild, Anne J. O'Brien, and Beth D. Tractenberg, acting as individuals, prepared those comments, although they are members of a subcommittee of ACTEC's International Estate Planning Committee. At the time of that submission, the comments had not been submitted to or reviewed by the governing body of ACTEC. The Executive Committee of the Board of Regents has now reviewed and approved those comments, and I am authorized to advise you that ACTEC endorses those comments completely and adopts them as its position in connection with the proposed legislation.
Very truly yours ,

Daniel H. Markstein, III
President

/pam

cc:    John Buckley: john.buckley@mail.house.gov
        Chris Javens: chris_javens@finance-rep.senate.gov
        Kase Jubboori: kase.jubboori@mail.house.gov
        Allen Littman: allen.littman@mail.house.gov
        Joshua Odintz: joshua_odintz@finance-dem.senate.gov
        ACTEC Executive Committee
        Mrs. Gerry A. Vogt, ACTEC Executive Director
        Ellen K. Harrison, Esq.