Seldom does the earth, moon, and stars align.

 1. A married couple can gift their combined $10 million applicable exclusion and avoid a combination of the three taxes.

2.   2010 Act Sets Gift Rules for Two Years But Leave the Future Unknown-is there Opportunity in these murky waters?

3.  Absent congressional action, the tax law reverts to the Tax Act of 2001 on January 1, 2013.  If history is consistent in 2012 the Congress may or may not reach agreement on a new gift tax. If agreement is reached it may be similar in timing to the 2010 Tax Act which passed in December of 2010 leaving the entire tax year for 2010 difficult to plan.
4. Remember that a tax law may be effective retroactively which makes 2012 especially difficult to project the terms of a new law.        3. Deficits pressure public policy to change revenue laws to exact greater taxes. This includes the gift tax.

5.  Thus significant opportunity exists in these two years to reduce the size of an estate by inter vivos gifting which reduces the amount subject to federal estate tax.