The IRS has released its revenue proposals, noting its policy priorities in the area of ​​estates and gifts, many of which carry over from previous years:

• Changing the generation pass-through (GST) transfer rules applicable to trusts that are designated as non-pass-through persons because they include a charitable beneficiary.
• Implementation of rules to limit the structure of payments for charitable annuity funds (CLAT) to avoid deferral of charitable payments at the expense of the charity.
• Treatment of loans to beneficiaries of GST trusts as distributions for GST and income tax purposes.
• It requires a minimum residual value of 25% and a term of 10 years for grantor-held annuity funds, among other types of trusts.
• Prohibition of deducting the estate tax value of promissory notes issued at the applicable federal minimum rate for income tax purposes.
• Treatment of carried interests as ordinary income.
• Prohibiting gain deferral on the exchange of real property used in a trade or business under the like-kind exchange rules and instead treating exchange gains in excess of a certain threshold as sales.