Deutsche Asset & Wealth Management Blanche Lark Christerson Managing Director, Senior Wealth Planning Strategist Tax Topics 2013 Table of Contents 2013 12/20/13 Budgets, tax reform and “extenders”; end of the year round-up 2013-12 11/15/13 The government shutdown, and selected inflation-adjusted numbers for 2014 and 2013-11 end-of-the-year planning points 10/07/13 A review of basic planning points 2013-10 08/30/13 Revised discussion of Windsor, reflecting guidance from the IRS and the Treasury 2013-09 Department, issued on August 29, 2013 08/28/13 United States v. Windsor. the Supreme Court rejects Section 3 of DOMA, which 2013-08 defines “marriage” as only between a man and a woman 07/01/13 Selected planning points: the now “permanent” $5 million exclusion, indexed for 2013-07 inflation, state estate taxes and “portable” spousal exclusions 05/29/13 Updated discussion of selected options to save for a child’s college education 2013-06 04/29/13 Selected tax provisions from President Obama’s Fiscal Year 2014 Budget 2013-05 03/21/13 Updated estate planning glossary and selected income tax terms 2013-04 02/20/13 Conservation easement flunks as charitable contribution (Be/k); “DD” and the cost of 2013-03 employer-provided health care; two important 100-year anniversaries; some lesser- known provisions of the American Taxpayer Relief Act 01/25/13 Selected numbers from official IRS 2013 inflation-adjustments (Rev. Proc. 2013-15); 2013-02 fagade easement has zero value as charitable deduction (Scheidelman) 7 HOUSE_OVERSIGHT_022330

01/10/13 Selected overview of the “American Taxpayer Relief Act of 2012” (H.R. 8): 2001 and 2013-01 2003 tax cuts largely made permanent, but higher taxes for the top 1% to 2% 2012 12/31/12 Proposed regulations on the 3.8% tax on “net investment income”; Wandry again, and 2012-09 how many gift tax dollars the “defined value” clause saved 11/30/12 The “fiscal cliff,” alternative minimum tax and transfer taxes; IRS “non-acquiesces’” in 2012-08 Wanadry; possible taxpayer relief for those affected by Hurricane Sandy 10/31/12 Countdown to the election; selected 2013 inflation-adjusted numbers and various 2012-07 planning points; Wandry appeal withdrawn 09/25/12 The looming “fiscal cliff? and the shape of possible future tax legislation; how NOT to 2012-06 substantiate a charitable deduction (Wohamed v. Commissioner); Wandry appealed 07/31/12 The Supreme Court's health care decision: The Affordable Care Act upheld 2012-05 06/11/12 Wanadry v. Commissioner. yes, another taxpayer victory using a “defined value” 2012-04 formula clause — but caution may be in order 04/19/12 Supreme Court arguments on the health care law; Medicare taxes taking effect in 2012-03 2013: 0.90% on the wages of “high earners” and 3.8% tax on “net investment income”; the Buffett Rule and the “Paying a Fair Share Act” (S. 2230) 03/08/12 Tax proposals on “high-income” taxpayers from President Obama's Fiscal Year 2013 2012-02 Budget and the Treasury Department’s “Green Book” 01/23/12 Estate of Petter v. Commissioner: another taxpayer victory using a “defined value” 2012-01 formula clause, and the legacy of Procter v. Commissioner 2011 12/02/11 “Super Committee” bows out; 2012 inflation-adjusted numbers and various planning 2011-09 points; the “Sensible Estate Tax Act of 2011” (H.R. 3467) 10/21/11 The American Jobs Act of 2011: the 28% limitation, the millionaires’ surtax, and the 2011-08 “Buffett Rule” 09/16/11 The Budget Control Act of 2011 (Pub. L. 112-25) and the “Super Committee”: reduce 2011-07 the deficit — or else! 07/28/11 How certain discretionary language almost made a credit shelter trust taxable in the 2011-06 trustee/beneficiary's estate (Estate of Chancellor v. Commissioner) 06/13/11 A Tax Court valuation case that illustrates just how far apart the experts can be, and 2011-05 how a judge evaluates those experts (Estate of Mitchell) 05/03/11 Additional thoughts on last December's 2010 Tax Act: lifetime gifts (GRATs, Sales to 2011-04 Defective Grantor Trusts and QPRTs) and how “credit shelter trusts” are still relevant despite the “portability” of a deceased spouse’s estate tax exclusion Tax Topics — Table of Contents — 2013 — 2 HOUSE_OVERSIGHT_022331

04/06/11 What it means to be a “statutory resident” of New York for income tax purposes — and 2011-03 how expensive that can be (Matter of Baker) 02/24/11 Updated “estate planning glossary” 2011-02 01/31/11 A discussion of “tax expenditures” and possible tax reform, based on reports from the 2011-01 President's Deficit Commission and the National Taxpayer Advocate 2010 12/23/10 Overview of the Tax Relief, Unemployment Insurance Reauthorization, and Job 2010-11 Creation Act of 2010 (Pub. L. 111-312): income tax and capital gains rates, tax-free distributions from IRAs to charity; estate and gift tax and GST provisions 11/30/10 Thoughts on the mid-term elections, and selected year-end planning points, along 2010-10 with some of the inflation-adjusted pension plan numbers for 2011; brief reminder of what low interest rates mean for certain planning techniques, including GRATs (grantor retained annuity trusts) and Sales to Defective Grantor Trusts 10/26/10 Estate of Tatum: another disclaimer gone awry — but taxpayer loses this time; 2010-09 possible timeline for retroactive reinstatement of estate tax and GST, based on Carlton, a 1994 Supreme Court estate tax case 09/14/10 Taxpayer successfully rescinds defective disclaimers and avoids significant gift tax 2010-08 liability (Breakiron); discussion of Bosch, the vintage case addressing when a state law holding is binding on the IRS 07/27/10 A discussion of next year’s likely return of “PEP” and “Pease” (indirect tax increases 2010-07 on higher earners) and the potential impact on charitable giving; two cases involving purported charitable gifts and a skeptical IRS: Hendrix and Free Fertility Foundation 07/01/10 A round-up of the still uncertain tax landscape: Sen. Bernie Sanders’ estate tax bill 2010-06 and its revenue raisers (consistent basis reporting, limits on valuation discounts and GRAT restrictions), “PAYGO” and Sen. Kyl’s estate tax proposal; Rep. Ryan’s “Roadmap”; NY drops “privity” requirement for executor’s suit against estate planning attorney (Schneider v. Finnman) 05/28/10 “Pierre II”. the Tax Court addresses the “step transaction doctrine” and valuation 2010-05 issues in a continuation of the Pierre v. Commissioner saga; valuation of fractional interests used in QPRTs (Ludwick v. Commissioner) 05/06/10 An updated discussion of some of the options to save for a child’s college education 2010-04 04/05/10 An overview of some of the provisions in the new health care legislation, particularly 2010-03 the new Medicare taxes; codification of “economic substance doctrine’; GRAT restrictions advance 02/28/10 President Obama's FY 2011 Budget — increases on higher earners, and estate and 2010-02 gift tax proposals: return to the 2009 estate tax regime, consistent values, modifying rules on valuation discounts and mandating minimum 10-year term and remainder interest for GRATs; under the “check-the-box” regulations, is a single member LLC disregarded for gift tax purposes? (Pierre v. Commissioner) Tax Topics — Table of Contents — 2013 — 3 HOUSE_OVERSIGHT_022332

01/26/10 The 2010 planning landscape: NO estate tax, GST or basis adjustment rules; what 2010-01 Congress may do; possible constitutional “due process” challenge; what can go wrong when documents are wrong about how property is titled (Beudert-Richard v. Richard) 2009 12/22/09 The imminent demise of the estate tax? Possible effect on formula provisions and the 2009-10 difficulties of modified carryover basis; extenders bill and carried interest; proposed stock transactions tax; importance of keeping beneficiary designations current (Kennedy v. DuPont SIP) 09/30/09 More on Roth IRA conversions: calculating what the taxable amount may be; how a 2009-08 “decoupled” state may tax a non-resident’s property, even if it’s passing to a surviving spouse; NY advisory opinion on non-resident’s proposed condo purchase (TSB-A- 08(1)M) 08/31/09 What may happen with estate tax repeal and tax-free IRA distributions to charity; 2009-07 early 2009 AMT “patch”; Roth IRA conversions in 2010 — restrictions will be gone so that anyone may convert a “regular” IRA to a Roth 07/28/09 Some pros and cons of several options to pay for health care reform; the case of the 2009-06 “tainted witness” and a will’s tax apportionment clause (Estate of Wu); how some states are dealing with economic adversity 06/15/09 OMB's “Analytical Perspectives” and Treasury Department’s “Green Book” offer 2009-05 insights on Obama tax proposals and outline of estate and gift tax proposals: consistent values, modifying rules on valuation discounts and minimum 10-year terms for GRATs; taxing employer-provided health care?; new mortality tables and QPRTs; New York’s increased taxes and estimated tax payments 04/20/09 The “Taxpayer Certainty and Relief Act of 2009” (S. 722) — makes lower income tax 2009-04 rates permanent, increases higher rates, and freezes the estate tax at 2009 levels; focus on whether Congress might reinstate the state death tax credit; new task force on tax reform 03/19/09 President Obama's FY 2010 budget proposal: higher rates, limits on itemized 2009-03 deductions and the personal exemption phase-out; the interaction of the regular tax with the AMT; historical income tax and capital gains tax rates; S. 394 would enhance the tax treatment of art and collectibles 02/09/09 Rep. Pomeroy’s estate tax bill (H.R. 436); basic planning points; basis adjustment 2009-02 rules, including modified carryover basis in 2010; “The Rangel Rule” (H.R. 735); intra- family loans 01/12/09 Suspension of 2009 required minimum distributions under The Worker Retiree and 2009-01 Employer Recovery Act of 2008 (Pub. L. 110-458): a brief mention of another “bad facts” limited partnership case (Hurford) Tax Topics — Table of Contents — 2013 - 4 HOUSE_OVERSIGHT_022333

2008 12/02/08 Prospective tax increases and their possible revenue implications; inflation-adjusted 2008-11 numbers for 2009 and selected planning points 11/04/08 The Emergency Economic Stabilization Act of 2008 (Pub. L. 110-343): AMT 2008-10 extenders and ISO relief, tax-free IRA distributions to charity, deduction for state and local sales taxes, broker basis reporting, and harmonizing preparer penalties for undisclosed positions; making lemonade out of lemons — coping with the market decline 09/30/08 A discussion of the upcoming $3.5 million estate tax exclusion, and how it affects 2008-09 planning in “decoupled” states, especially for married couples 08/29/08 A selected review of major tax legislation during the Bush administration, and a 2008-08 snapshot of the tax proposals of Senators McCain and Obama 07/31/08 No discount for “restricted management accounts” (Rev. Rul. 2008-35); final regs on 2008-07 “grantor retained interest trusts” (T.D. 9414) 06/30/08 Charitable remainder trusts and UBTI: final regs (T.D. 9403); charitable lead trusts 2008-06 and “tiering” provisions: proposed regs (REG-101258-08) 05/30/08 Supreme Court holds that muni bonds still tax free (Kentucky v. Davis); IRS issues 2008-05 proposed regs on alternate valuation (REG-112196-07; Kohler v. Commissioner) 04/28/08 The awful AMT and its disappearing exemption; Notice 2008-22 and a trust grantor’s 2008-04 “nonfiduciary” power to swap trust property for property of equivalent value; planning techniques that work well in a low-interest rate environment 03/31/08 Disclaimers and self-adjusting valuation clauses (Christiansen) 2008-03 02/26/08 More on the new preparer penalties: Notice 2008-13 2008-02 01/28/08 Supreme Court affirms that trust investment advisory fees subject to 2% floor 2008-01 (Knight); wash sale rules and IRAs; survivorship and the marital deduction (Lee) 2007 12/21/07 AMT patch, cont’d.; 11" Circuit reverses Tax Court: built-in capital gains tax 2007-12 liability reduces value of closely held corporation: Estate of Jelke (General Utitilies doctrine; willing buyer-willing seller; IRA implications) 11/20/07 AMT patch; inflation-adjusted numbers for 2008 and planning points; 0% rate for 2007-11 dividends and capital gains 10/26/07 Preparer penalties: the new rules under the Small Business and Work Opportunity 2007-10 Act of 2007; transition rules under Notice 2007-54 09/28/07 Charlie Rangel’s proposal; AMT and estimated tax; taxing “carried interest” 2007-09 08/31/07 Saving for college: the “kiddie tax” and the pros and cons of different savings vehicles 2007-08 Tax Topics — Table of Contents — 2013 — 5 HOUSE_OVERSIGHT_022334

07/31/07 Davis v. Kentucky Revenue Department — Supreme Court to examine muni bond 2007-07 taxability; proposed regs on trust investment fees and the 2% floor (REG-128224-06) 06/28/07 Proposed regs on grantor retained income trusts (REG-119097-05); why timing of 2007-06 payments matters; why there’s a 7520 rate; Rudkin update 05/31/07 “Kiddie tax” changes; custodial accounts; “pay-go”; whither the estate tax; get a good 2007-05 valuation expert! (Kimberlin) 04/27/07 2™ Circuit affirms that trust investment fees subject to 2% floor: Rudkin 2007-04 03/29/07 IRS Clarification: non-spousal rollovers and tax-free IRA distributions to charity 2007-03 (Notice 2007-7); tax patents; Chuck Grassley on the AMT and the “tax gap” 02/28/07 Estate Planning Glossary 2007-02 01/30/07 The “First 100 Hours”; President Bush’s health care proposals; 2006 Annual Report of 2007-01 the National Taxpayer Advocate 2006 12/29/06 The Tax Relief and Health Care Act of 2006 (Pub. L. 109-432): “extenders”; health 2006-11 savings accounts; AMT refundable credit; charitable remainder trusts and UBTI; permanent capital gain treatment for self-created musical works 11/22/06 The mid-term elections; 2007 inflation-adjusted numbers 2006-10 10/23/06 More on the Pension Protection Act of 2006: fractional interest gifts and $100,000 tax- 2006-09 free IRA contributions to public charities; Charlie Rangel and AMT reform; Connecticut marital deduction for same-sex couples 09/08/06 The Pension Protection Act of 2006 (Pub. L. 109-280): selected retirement and 2006-08 charitable provisions 07/31/06 Estate Tax and Extension of Tax Relief Act of 2006 (H.R. 5970); Illinois decoupling 2006-07 (McGinley v. Madigan); non-resident income taxation and out-of-state property 06/27/06 Permanent Estate Tax Relief Act of 2006 (PETRA, H.R. 5638) 2006-06 05/31/06 Tax Increase Prevention and Reconciliation Act of 2005 (Pub. L. 109-222): “kiddie 2006-05 tax”; conversions to Roth IRAs; expatriate income and housing exclusion; capital gains treatment for self-created musical works 04/28/06 The AMT and stock options: capital loss carryback prohibitions apply to AMT as well 2006-04 (Merlo); attempted assignment of income fails (McManus); assignment of income: non-qualified stock options and charitable remainder trusts 03/29/06 4" Circuit upholds IRS win in Chawla, but “insurable interest” issue still dangles 2006-03 02/22/06 Charitable Remainder Trust Safe-Harbor (Notice 2006-15); more on prepaid tuition; 2006-02 debts, forgiveness and taxes Tax Topics — Table of Contents — 2013 - 6 HOUSE_OVERSIGHT_022335

01/27/06 Prepaid tuition (PLR 200602002); gift and estate tax reminder; “Personal Revival 2006-01 Trusts” for cryonauts 2005 12/27/05 Tax Reform Panel Recommendations; Ron Wyden’s “Fair, Flat Tax Act of 2005” 2005-12 11/18/05 Hurricane Katrina Provisions; 2006 inflation-adjusted numbers; sale of remaining 2005-11 lottery payments is not a sale of a “capital asset” (Prebola) 10/18/05 Saving for College — round-up of options 2005-10 09/30/05 Ittleson — New York taxes sale of non-resident’s artwork 2005-09 09/08/05 Estate tax thoughts; GST consequences of taxable trust renunciation (PLR 2005-08 200532024); note about the “rule against perpetuities” 07/29/05 Strangi — 5" Circuit upholds IRS win in Texas FLP case 2005-07 06/30/05 Circular 230 2005-06 05/27/05 Estate planning glossary; Washington state’s new estate tax 2005-05 04/20/05 New Jersey loses on decoupling case (Oberhand); retroactive tax changes 2005-04 (Nationsbank); charitable remainder trust “safe harbor” rules and the right of election (Rev. Proc. 2005-24) 03/28/05 Insurable interests and trusts: Chawla; “frivolous arguments to avoid when paying 2005-03 taxes” (Notice 2005-30) 02/18/05 Washington State decoupling struck down: Hemphill 2005-02 01/28/05 Social security, the estate tax and tax reform; several cases: Banks (contingent 2005-01 attorney's fees); Harkins (“corporation sole”); Davis (marital deduction) 2004 12/28/04 The Barnes Foundation 2004-15 11/24/04 2005 inflation-adjusted numbers; how a low 7520 rate affects planning techniques 2004-14 11/05/04 Tax reform: flat tax and consumption tax; American Jobs Creation Act deductions for 2004-13 sales tax and attorneys’ fees; New York tax law change: non-resident’s sale of co-op now taxable 10/08/04 The Working Families Tax Relief Act of 2004 (H.R. 1308): extension through 2010 of 2004-12 10% and 15% brackets; that “ridiculously complex” tax code; a word on PORC; reminder about low 7520 rates 09/10/04 Turner v. Commissioner (formerly Thompson): 3d Circuit affirms IRS Tax Court win 2004-11 against FLP (family limited partnership); Turner contrasted with Kimbell Tax Topics — Table of Contents — 2013 — 7 HOUSE_OVERSIGHT_022336

08/03/04 Tax Court says stock transfers to FLP are indirect gifts (Senda); co-op’s real estate 2004-10 taxes not deductible against AMT (Ostrow and Guterman) 07/14/04 IRS addresses grantor trust rules and implications of tax reimbursement clauses 2004-09 (Rev. Rul. 2004-64); LUST tax 06/25/04 H.R. 4520, the export bill; proposals for state and local sales tax deduction and 2004-08 deferred compensation; House bills; temporary Connecticut decoupling; 7520 rate chart 05/28/04 Kimbell v. U.S. — 5" Circuit hands taxpayer a victory in FLP case; how the applicable 2004-07 federal rates are determined 04/28/04 Export bill: economic substance doctrine, expanded “kiddie tax”; no dice on offsetting 2004-06 gambling losses (TAM 200417004); QSLOB election 04/02/04 President Bush’s 2005 budget takes aim at 529 plan “loopholes”; deductibility of 2004-05 attorneys’ fees — Supreme Court grants cert on Banaitis and Banks 03/18/04 Impact of 2001 and 2003 tax law changes and interplay with AMT; reminder about low 2004-04 7520 rates 02/27/04 More thoughts on “decoupling”: New York, New Jersey and Connecticut — the power 2004-03 of lifetime gifts; pro-rating the tax on a New York trust that changes situs 02/03/04 Tax clause nightmare: Lurie v. Commissioner, or the pain of charging taxes to a non- 2004-02 taxable share; interrelated computations 01/14/04 New York fiduciary income tax and trust situs: Estate of William Rockefeller and 2004-01 Matter of Harriet Bush; codification of Mercantile 2003 12/19/03 More changes on New York’s 529 Plan; intra-family loans: term and demand loans, 2003-21 and forgiving them; note on William Roth and John Breaux 11/26/03 Inflation-adjusted numbers for 2004; charitable remainder trusts, “ordering rules” 2003-20 and qualified dividends (REG-110896-98) 11/10/03 Connecticut “decouples” for a bit; New York and New Jersey “decoupling” — 2003-19 disclaimers and contingent QTIPs; changes to New York's 529 Plan 10/24/03 IRS acquiesces in Walton GRAT decision (Notice 2003-72); Social Security and “full 2003-18 retirement age” 10/10/03 The Independent 529 Plan 2003-17 09/26/03 IRS guidance on reporting requirements for substitute dividends (Notice 2003-67); 2003-16 the “Wall Street Rule”; tax reward money taxable (Roco) 09/05/03 The fall legislative agenda; saving for a child’s college education 2003-15 Tax Topics — Table of Contents — 2013 - 8 HOUSE_OVERSIGHT_022337

08/06/03 Strangi [il — the Tax Court thumps taxpayer in Texas FLP case 2003-14 07/23/03 7" Circuit upholds IRS win in Hack/: no annual exclusion for gifts of LLC interests 2003-13 07/01/03 New York’s “tax traps” regarding the estate tax, GST and non-residents 2003-12 06/16/03 More on JGTRRA, qualified dividends and the new tax rates 2003-11 06/06/03 JGTRRA: lower rates, qualified dividends, increased child tax credit; marriage penalty 2003-10 relief; increased AMT exemption; chart with phase-outs of the AMT exemption amounts 05/16/03 Jobs and growth bill; trust’s investment fees subject to 2% floor (Scott); tax 2003-09 apportionment (PNC Bank v. Roy); Michigan and the TPT credit (Lacks v. Michigan Department of Treasury) 05/02/03 Jobs and growth bill; flat tax proposals; tax apportionment (Kurait) 2003-08 04/11/03 Budget update; estate tax pitfalls for non-resident aliens (Fung); “indirect skips” and 2003-07 the GST; QTIP election boo-boo (PLR 200314012); early CRUT termination and capital gain (PLR 200314021) 03/28/03 Budget news; contingent attorneys’ fees (Raymond) — and how AMT interacts with 2003-06 them 03/13/03 Budget and legislative update; marital deduction mess-up (Davis); limited education 2003-05 no defense against estate tax deficiency (Koester) 02/28/03 Taxpayer's SCIN works (Estate of Dulio Costanza); SCIN contrasted with private 2003-04 annuity; IRS loses on “joint-spousal GRATs” (Cook) 02/14/03 Details on Fiscal Year 2004 Budget, including various proposed savings accounts 2003-03 (lifetime, retirement and employer-sponsored); impact on 529 plans; a closer look at arguments in favor of tax-free dividend proposal 01/31/03 State of the Union address and tax-free dividend proposal; CBO’s deficit numbers; 2003-02 Sen. Daschle on the Democratic plan; /s all retirement plan income “effectively” tax- free? (KD 3761); “decoupling” in Nebraska and Kansas 01/16/03 President Bush’s job creation plan and tax proposals, including tax-free dividends; 2003-01 Sen. Feinstein on freezing the top rate; JCT lists expiring provisions;House rules to require macroeconomic analyses; dynamic scoring 2002 12/19/02 New faces: John Snow and Steven Friedman; adjustment clause too much like 2002-22 Procter — Mom can't take back gift (TAM 200245053); non-immigrant visa doesn’t preclude domicile (Estate of Jack); payments to Holocaust survivors permanently exempted from income tax 11/27/02 Our “abominable” tax code and how it got that way; Lindy Paull’s departure; how 2002-21 7520 rates affect planning techniques — why GRATs work better with lower rates and QPRTs don't Tax Topics — Table of Contents — 2013 - 9 HOUSE_OVERSIGHT_022338

11/19/02 Aftermath of the mid-term elections and the AMT; estate tax issues; inflation-adjusted 2002-20 numbers for 2003 10/25/02 Run-down on proposed legislation: the CARE and NESTEG bills; next year’s FICA; 2002-19 low 7520 rates and planning: QPRTs, CLATs, CRATs, GRATs and charitable gift annuities 09/20/02 Possible permanency of 2001 Tax Act and its education provisions;“decoupling’: 2002-18 D.C., Massachusetts, New Jersey and New York 09/04/02 Treasury ends “abusive” split-dollar scheme (Notice 2002-59) 2002-17 08/29/02 CBO’s budget numbers and stimulus proposals; IRA discussion correction — comment 2002-16 from Cathy Vohs of the IRS 08/01/02 CARE Act progresses — proposed gifts to charity from IRAs 2002-15 07/23/02 Corrections on IRA discussion; single life distribution table 2002-14 07/18/02 Corrected discussion on the final minimum distribution regs 2002-13 07/02/02 The debt limit increase; IRS retreats from imposing FICA or FUTA taxes on ISOs 2002-12 (Notice 2002-47) 06/21/02 Attempts to make 2001 Tax Act permanent; efforts at estate tax reform; law-school 2002-11 expenses not deductible (Galligan); ignorance of the law is no excuse — “innocent spouse’ relief denied (Mitchell) 05/24/02 The “sunset” provision of the 2001 Tax Act; new IRA distribution tables 2002-10 04/18/02 Thoughts on 529 Plans; IRS issues final rules on IRA distributions; “decoupling”: 2002-09 Maryland, Nebraska and New York 04/09/02 Tax Court denies annual exclusion for gifts of LLC interests (Hack/); Florida says 2002-08 goodbye to estate tax revenues 03/20/02 Senate Finance Committee hearing on tax shelters; Joint Committee on Taxation 2002-07 report on shelters and judicial doctrines used against them 03/15/02 Stimulus bill passes; bill to freeze some of 2001 Tax Act; CBO and OMB revenue 2002-06 projections; Concord Coalition suggestions about fiscal year 2003 budget; GRAT includibility under IRC Sec. 2039 (TAM 200210009); Vermont “decoupling”; the GST and “indirect” skips — the opt-out 02/28/02 Tax shelter amnesty (Announcement 2002-2); whither the corporate income tax?; IRS 2002-05 permits early CRUT termination (PLR 200208039) and tax treatment of early termination (PLR 200127023); IRS information on Victims’ Relief Bill (Publication 3920); New York City’s cigarette tax 02/22/02 President Bush's fiscal year 2003 budget; Senate vote on estate tax repeal; the 2002-04 shrinking surplus; increase in debt ceiling; taxability of frequent flyer miles (Announcement 2002-18); cigarette taxes Tax Topics — Table of Contents — 2013 — 10 HOUSE_OVERSIGHT_022339

01/31/02 Victims’ Relief bill signed — planning points; bill to reinstate marital deduction for non- 2002-03 citizen spouses (H.R. 3575); the state death tax credit and “decoupling”: Minnesota, Rhode Island and Wisconsin 01/25/02 IRS Notice on split-dollar life insurance (Notice 2002-8) 2002-02 01/11/02 Tom Daschle speech on the economy; 2001 Report of the National Taxpayer 2002-01 Advocate 2001 12/21/01 The stimulus package; the Victims of Terrorism Relief Act; inflation-adjusted numbers 2001-25 for 2002 11/30/01 More on Victims of Terrorism bill (history of prior such bills); applicability of FICA and 2001-24 FUTA taxes to ISOs (incentive stock options): proposed regulations (REG-142686-01) and Notices 2001-72 and 2001-73; the AMT and ISOs 11/26/01 Stimulus package stalls; Victims’ Relief bill progresses; 18% capital gains tax rate and 2001-23 gain on principal residence exclusion (Revenue Ruling 2001-57) 10/31/01 More thoughts on the Victims of Terrorism relief bill; FICA increase; France and the 2001-22 VAT 10/24/01 Stimulus plans; budget shortfalls in California, Florida, New York and North Carolina 2001-21 09/28/01 9/11 aftermath: Victims of Terrorism Relief Act 2001-20 09/04/01 More on “timing” and the new estate tax rates; the phase-out of the state death tax 2001-19 credit 08/07/01 AMT ISO relief?; “timing” and the new estate tax rates; the tax rebates 2001-18 08/02/01 Possible repeal of the “sunset” provision and the estate tax; GST “indirect” skips and 2001-17 deemed allocations 07/25/01 GST changes under 2001 Tax Act 2001-16 07/10/01 Two unfavorable IRA rulings: sons can’t be default “designated beneficiaries” 2001-15 (PLR 2001260410) and daughter can’t name herself as Mom’s designated beneficiary after Mom’s death (PLR 200126036); new IRA rules wouldn't necessarily have made a difference 06/29/01 Some of the numbers behind the 2001 Tax Act 2001-14 06/04/01 Rundown on EGTRRA (the 2001 Tax Act) 2001-13 05/22/01 Gifts to non-grantor trusts under the “Relief” bill; Neal tries to shut down swap funds 2001-12 (H.R. 1785) 05/18/01 Rundown on the “Relief” bill; the “Byrd rule” 2001-11 Tax Topics — Table of Contents — 2013 — 11 HOUSE_OVERSIGHT_022340

04/20/01 Costs of the “Death Tax Elimination” bill; the Joint Committee on Taxation and 2001-10 revenue estimates; estate tax reform bills; Rangel bill would make state and local taxes deductible against AMT 04/13/01 The costs of estate tax repeal 2001-09 04/11/01 President Bush’s tax proposals, H.R. 8, “The Death Tax Elimination Act of 2000,” 2001-08 carryover basis and “dynamic” versus “static” scoring 03/23/01 Competing stimulus bills and possible estate tax relief 2001-07 03/07/01 Stimulus bill in the making; IRA hardship exemption fails (Gallagher); tax fraud 2001-06 conviction and sentencing of Dorothy and George Henderson; office space for the Clinton Foundation 02/05/01 Projected budget surpluses; President Bush’s tax plan; possible estate and gift tax 2001-05 repeal 01/30/01 Clarification on new proposed IRA regs 2001-04 01/24/01 Appendix with new IRA distribution period 2001-03 01/22/01 Senate Finance Committee takes shape; new proposed regs on IRA distributions 2001-02 (REG-130477-00 and REG-130481-00) 01/10/01 Tax-writing committees take shape; possible tax legislation; IRS loses Walton GRAT 2001-01 case; how tax credits lard up the tax code; joint spousal revocable trust wins and loses 2000 12/20/00 The $1.3 trillion tax cut; inflation-adjusted numbers for 2001 2000-19 11/29/00 Thoughts on the new faces in Washington; candidates for Chairman of the House 2000-18 Ways and Means Committee 11/22/00 The uncertain outcome of the elections; compromise bill on the foreign sales tax 2000-17 regime; standard mileage rates 11/17/00 Election outcome unknown, but what the tax-writing committees may look like 2000-16 10/30/00 House passes tax bill, Clinton promises veto; NY streamlines tuition savings plan; 2000-15 FICA increases and Social Security funding 10/18/00 Details on 18% capital gains tax rate; deduction and credit for college tuition; 2000-14 conviction of Dorothy and George Henderson for tax fraud 10/02/00 H.R. 1102, the “Retirement Security and Savings Act of 2000”; estate tax update 2000-13 Tax Topics — Table of Contents — 2013 — 12 HOUSE_OVERSIGHT_022341

09/15/00 Override on “marriage penalty” veto fails; Republican edge in House 2000-12 narrows;“surviving spouse” in same-sex relationship loses 50% co-ownership argument (Estate of Horstmeier); credit for tax on prior transfers doesn't fly (Estates of Harrison); Gov. Jesse Ventura on Minnesota public school education 09/08/00 Override on estate repeal veto fails; final GRAT regulations issued (T.D. 8899, 26 2000-11 CFR Part 25); settlement fees and tax apportionment (Estate of Esther Brabson); dependency exemption for kidnapped child (ILM 200034029) 08/07/00 Strategies for passing tax reform; New Hampshire upholds inheritance tax 2000-10 07/14/00 Thoughts on possible estate tax repeal; New Hampshire House overrides inheritance 2000-09 tax repeal veto; the problem of joint-ownership (PLR 200034029); draft legislation to permit fair market value deduction for charitable contributions by artists and authors (S. 2781) 06/29/00 Projected surpluses; estate tax repeal movement 2000-08 06/09/00 New Hampshire governor vetoes inheritance tax repeal; IRS ruling on a “5 & 5” 2000-07 power: ever-increasing ownership of the trust (PLR 200022035); IRS wins two cases: gifts to a corporation don’t qualify for annual exclusion (Stinson); “economic benefit” doctrine doesn’t accelerate taxability of lottery winnings (Thomas) 05/19/00 H.R. 8 and estate tax repeal; embezzled money is taxable income (Amini); no 2000-06 “married filing jointly” available for taxpayer in same-sex relationship (Mueller) 05/15/00 Estate tax valuation of a disputed claim: Estate of Algerine Smith. Commissioner — 5" 2000-05 Circuit reverse Tax Court 04/13/00 IRS goes after “ghoulish” charitable lead trusts (REG-100291-00; new tax shelter 2000-04 listings apply to individuals as well as corporations; IRS permits disclaimer to change IRA beneficiaries (PLR 200013041); community property IRA distribution to ex- spouse taxable to IRA owner (Bunney); charitable bequest of non-qualified stock options taxable to charity, not estate (PLR 20012076) 03/24/00 Donees subject to transferee liability (Armstrong); converting NIM-CRUTs to CRUTs 2000-03 (Notice 99-31); discharge of GRAT liability (TAMs 200010010 and 20001 1005) 02/28/00 Corporate tax refunds are up; taxpayer wins Texas partnership case (E/sie Church v. 2000-02 United States) 0/11/00 President Clinton’s final budget (fiscal year 2001); attempted casualty loss for 2000-01 property next to O.J. Simpson’s estate (Chamales) Tax Topics — Table of Contents — 2013 — 13 HOUSE_OVERSIGHT_022342

Blanche Lark Christerson is a managing director at Deutsche Asset & Wealth Management in New York City, and can be reached at [email protected]. The opinions and analyses expressed herein are those of the author and do not necessarily reflect those of Deutsche Bank AG or any affiliate thereof (collectively, the “Bank”). Any suggestions contained herein are general, and do not take into account an individual’s specific circumstances or applicable governing law, which may vary from jurisdiction to jurisdiction and be subject to change. No warranty or representation, express or implied, is made by the Bank, nor does the Bank accept any liability with respect to the information and data set forth herein. The information contained herein is not intended to be, and does not constitute, legal, tax, accounting or other professional advice; it is also not intended to offer penalty protection or to promote, market or recommend any transaction or matter addressed herein. Recipients should consult their applicable professional advisors prior to acting on the information set forth herein. This material may not be reproduced without the express permission of the author. "Deutsche Bank" means Deutsche Bank AG and its affiliated companies. Deutsche Asset & Wealth Management represents the asset management and wealth management activities conducted by Deutsche Bank AG or its subsidiaries. Clients are provided Deutsche Asset & Wealth Management products or services by one or more legal entities that are identified to clients pursuant to the contracts, agreements, offering materials or other documentation relevant to such products or services. Trust and estate and wealth planning services are provided through Deutsche Bank Trust Company, N.A., Deutsche Bank Trust Company Delaware and Deutsche Bank National Trust Company. © 2013 Deutsche Asset & Wealth Management. All rights reserved. 017075 121913 Tax Topics — Table of Contents — 2013 — 14 HOUSE_OVERSIGHT_022343