Estate and Gift Taxation

Estate and Gift Taxation, now in its fifth edition, provides teaching materials for a course on the U.S. transfer tax system as it exists following enactment of the One Big Beautiful Bill Act of 2025. In addition to addressing pronounced changes to the unified credit landscape introduced by the 2025 legislation, the fifth edition includes coverage of recent regulatory and case law developments.

The text opens with an overview of the federal transfer tax regime, one intended to introduce students to the basic structures of the estate tax, gift tax, and generation-skipping transfer (GST) tax. After this introduction, the text proceeds to examine the estate tax and gift tax bases primarily in a context-specific (e.g., life insurance, retained-interest transfers, marital transfers) manner, and the majority of the text is devoted to these topics. The text then transitions to a discussion of the GST tax base and allocation of the GST tax exemption, followed by a discussion of the special valuation rules under Chapter 14. The text closes with a chapter devoted to the application of the U.S. transfer tax regime in the international setting.

The text is structured through 27 discrete chapters, and the chapter headings supply a reasonable course syllabus. Each chapter closes with a set of sophisticated, practice-oriented problems that require students to spot and resolve issues that would be encountered in an estate planning practice. Adopters of the text will have access to a Teacher's Manual that provides thorough answers to the practice-oriented problems included at the end of each chapter.

Brant Hellwig is Professor of Tax Law and Director of the Graduate Tax Program at New York University School of Law.

Robert Danforth is the John Lucian Smith Jr. Memorial Professor of Law, retired, at the Washington and Lee University School of Law.

Catherine Ford is an Associate with Davis Polk & Wardwell LLP.