This article explores the gift tax consequences of an exchange of promissory notes between family members when interest rates have dropped from when the original or old note was issue to the present time when the new note is issued.
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Mr. Blattmachr is a Principal in ILS Management, LLC and a retired member of Milbank Tweed Hadley & McCloy LLP in New York, NY and of the Alaska, California and New York Bars. He is recognized as one of the most creative trusts and estates lawyers in the country and is listed in The Best Lawyers in America. He has written and lectured extensively on estate and trust taxation and charitable giving.
Mr. Blattmachr graduated from Columbia University School of Law cum laude, where he was recognized as a Harlan Fiske Stone Scholar, and received his A.B. degree from Bucknell University, majoring in mathematics. He has served as a lecturer-in-law of the Columbia University School of Law and is an Adjunct Professor of Law at New York University Law School in its Masters in Tax Program (LLM). He is a former chairperson of the Trusts & Estates Law Section of the New York State Bar Association and of several committees of the American Bar Association. Mr. Blattmachr is a Fellow and a former Regent of the American College of Trust and Estate Counsel and past chair of its Estate and Gift Tax Committee. He is author or co-author of eight books and more than 500 articles on estate planning and tax topics.
Among professional activities, which are too numerous to list, Mr. Blattmachr has served as an Advisor on The American Law Institute, Restatement of the Law, Trusts 3rd; and as a Fellow of The New York Bar Foundation and a member of the American Bar Foundation.
Bridget J. Crawford is a Professor of Law at the Elisabeth Haub School of Law at Pace University, and author of the 2020 article “Blockchain Wills” in the Indiana Law Journal. Professor Crawford teaches Federal Income Taxation; Estate and Gift Taxation; and Wills, Trusts and Estates. Her scholarship focuses on issues of taxation, especially wealth transfer taxation; property law, especially wills and trusts; tax policy; and women and the law. Prior to joining the Pace faculty, Professor Crawford practiced law at Milbank Tweed Hadley & McCloy LLP in New York (now Milbank LLP). Her practice was concerned with income, estate and gift tax planning for individuals, as well as tax and other advice to closely-held corporations and exempt organizations.
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