An estate planning question

[appelman]

A taxpayer has an estate valued at 4M. She makes 3M of gifts (beyond the annual limit). This leaves her a residual estate of 1M and a residual unified credit corresponding to 2M. A few years from now, the unified credit is reduced from 5M to 2M. What is the taxpayer's remaining credit: 2M? 0? -1M?

[Kram BergGold]

It depends

The anser dependsd how Congress writes the next revision to the Estate Tax law. There is not answer at this time. One can only hope that gifts made prior to any reduction to the credit will be grandfathered.