2010 Estate Tax Alert - Retroactively Imposed is Unconstitutional

For 10 years the estate tax was set in law to bewhat should be done for years following 2010. The
abolished in 2010. If congress didn't act to keep itreversion to the 2000 law was just to leave an estate
abolished or modify it for 2011 and beyond, then thetax law in place for abolishment or modification.
2011 estate tax would just revert to that of 2000. NowBut for 10 years, the legislature has done nothing about
congress is considering retroactively imposing anestate tax laws beyond 2010. This is a disgrace in
estate tax for 2010 later in 2010. This article updatesitself. That's because estate taxes can rob a wealthy
you on the present rates and explains that thisestate of up to half its value. And it takes several
retroactive change is unconstitutional.years - and often far more - to put effective estate
Just so you know, there's no estate tax andplanning into effect. And now, well into 2010, legislators
generation skipping (GST) tax in 2010 by law. Sinceare considering retroactively changing the 2010 estate
estate, GST, and lifetime gift taxes generally tax valuelaw.
above an exemption amount, we can say that theThere's no justification of retroactively changing the
2010 estate, GST, and lifetime gift taxes have2010 law not only because the original intent of the law
exemption levels of unlimited, unlimited, and $1 million,is consistent with its operation, but there are reasons
respectively. The value of gifts beyond the $1 millionthat changing it may possibly serve improper motives
exemption level is taxed at up to 35%.(an issue brought up in the Supreme Court case law
Without congressional action, the 2011 estate, GST, andabove) of congressman.
lifetime gift taxes exemption levels will go to $1 million,Motives - proper or not - may be associated with
$1 million (including lifetime gift), and $1 millioncontribution money to their election campaigns from
respectively. The top rates of each of these are 55%.special interest groups who seek influence on how the
But that's all liable to change either before 2011 turnslaws should be changed. Laws that require imminent
the corner of after.action frantically draw special interests to donate that
Changing 2010 taxes retroactively should bemuch more. The more congress can keep the carrot
considered unconstitutionaldangling, the more campaign contributions which may
Congress in its audacity may change the 2010 estatebe forthcoming. Clearly, congress has created this
tax laws late 2010 retroactively to Jan 1, 2010. Somecircumstance by their own inaction.
consider this retroactive change constitutional. TheyIf you recognize the unconstitutionality of this
cite Supreme Court case law in U.S. vs Carlton (1994)retroactive change in the 2010 estate law, you ought
that deals with a complicated estate tax deduction fornot to support any congressman who votes for it. The
an ESOP transaction. A retroactive law affecting thisunconstitutionality of retroactive laws should be
situation was upheld by the court to maintain the intentobvious to them - not to mention the average citizen.
of the original law - and that no improper motive forTrying to pass such laws undermines justice and
upholding the retroactive law was found.fairness - no matter what reason they proffer. Proper
But, the operation of the 2010 estate tax law reflectsor improper motives for passing retroactive laws may
no mistaken intent of those who fashioned andreap them benefits - but it'll be at the expense of the
passed that law. The clear intent of the law was to docitizenry - even if it's later overturned by the Supreme
away with estate tax. It left it to legislators to reviewCourt.