Robbie Ottley (J.D. 2024, Georgia), Note, GRATuitous Wealth: How Wealth Transfer Tax Avoidance Contributes to America's Unwinding, 58 Ga. L. Rev. 1347 (2024): 

In an era of increasing economic concentration, ultrawealthy Americans overwhelmingly pay taxes at a lower rate than their fellow taxpayers. Using tax avoidance mechanisms, the ultrawealthy cling tightly to their wealth, worsening economic inequality. A particular culprit is the ultrawealthy’s avoidance of generational wealth transfer taxes through mechanisms like the grantor retained annuity trust, or GRAT. Since 2000, GRATs have exploded in use, and estimates of the tax avoided through this mechanism range from hundreds of billions to trillions of dollars.

By exacerbating economic inequality, GRATs and other transfer tax avoidance mechanisms accelerate the socioeconomic and cultural fracturing that has been called America’s unwinding. This Note proposes the elimination of GRATs as a matter of basic fairness, as a method of reducing wealth inequality, and as a step toward weaving American society back together.

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