Under the American Taxpayer Relief Act of 2012 (ATRA), the federal gift, estate and generation skipping transfer (GST) tax exemptions of $5 million for individuals and $10 million for married couples (subject to an inflation adjustment) were made permanent, as was portability for the estate and gift tax exemptions. As a result of portability and the increased exemptions, it’s estimated that less than 0.2 percent of all estates will now be subject to federal estate tax.1 With fewer clients in need of transfer tax planning, estate planning attorneys find themselves re-positioning and re-evaluating their practices.