Samuel R. Scarcello (J.D. 2013, Northwestern), Comment, Transfer Taxes in Flux: A Comparison of Alternative Plans for GRAT Reform, 107 Nw. U. L. Rev. 321 (2012):

Estate and gift taxes may be a topic of national discussion, but
few Americans are familiar with the methods taxpayers utilize to minimize
these taxes. For decades, the Internal Revenue Code has
rewarded taxpayers who employ complex transfer tax strategies that take
advantage of “estate freeze” techniques, which can reduce or even eliminate
the taxes imposed on large wealth transfers. One particularly popular
technique, the grantor retained annuity trust (GRAT), facilitates tax savings
for individuals who plan in advance of significant asset appreciation.
Regrettably, such tax savings fail to conform to the widely held belief that
taxpayers of comparable income or wealth should pay similar taxes. Aiming
to tighten the rules on GRATs, President Obama has repeatedly introduced
reform proposals, but each time, he has neglected to address the technique’s
biggest vulnerability to abuse: that it allows ultra-wealthy individuals to
shield unlimited amounts—potentially billions of dollars—from the transfer
taxes that other Americans must pay. This susceptibility to aggressive
planning undermines the spirit of the Code and deprives the government of
much-needed tax revenue. Recognizing that GRATs fit snugly within a
larger body of interrelated tax provisions, this Comment advocates for the
imposition of a lifetime limit on tax-free GRAT transfers, a solution that
hampers the technique’s more dubious uses while preserving, to the greatest
extent possible, its creation of an incentive to invest in entrepreneurial
activity.