Lora G. Davis has recently published an article in the Texas Tax Lawyer journal regarding planning and compliance issues surrounding portability of a deceased spouse's unused estate and gift tax exemption. The article serves as a thorough survey of the technical requirements of making the election, as well as the published regulations elucidating their application.
Of particular note is the section regarding ethical and advising issues that may arise for estate planning attorneys.
See Lora G. Davis, "Portability - Planning and Compliance Issues," Texas Tax Lawyer (Spring 2013).
Posted by Conan Yuzna, Associate Editor, Wealth Strategies Journal.