Brent and Rachel discuss several themes circulating in the media (conventional and social). First, they discuss the proposed Billionaire Tax and how it appears to look a lot like the existing PFIC rules. Second, they discuss the review of GRATs, IDGTs, valuation discounts, and CLATs used by Phil Knight, as discussed in Businessweek https://www.bloomberg.com/features/how-billionaires-pass-wealth-to-heirs-tax-free-2021/.

After recording, the Senate Finance Committee released the text of the billionaire tax, which can be found here:

Click to access Billionaires%20Income%20Tax.pdf