ACTEC is pleased to submit this recommendation to substantially revise IRC Section 6166 and to propose the enactment of a new IRC Section 6166A to address the important issues related to providing deferral treatment for federal estate tax and generation-skipping transfer tax attributable to closely held business interests. As Congress considers legislative proposals related to the transfer tax system, the enclosed Report provides analysis regarding changes that, in the opinion of ACTEC, would improve the administration of the estate tax deferral regime and provide a new deferral opportunity with respect to generation-skipping transfer taxes.
ACTEC’s comments and recommendations are set forth in the attached Report, which is the product of nearly a decade of research and analysis on this topic.