Richard Posner 360x1000
Margaret Fuller3 360x1000
George M Cohan and Lerarned Hand 360x1000
2falsewitness
2jesusandjohnwayne
storyparadox3
Margaret Fuller4 360x1000
1gucci
1jesusandjohnwayne
13albion
3albion
3confidencegames
George F Wil...360x1000
11albion
5albion
9albion
Samuel Johnson 360x1000
2paradise
1transcendentalist
3defense
Brendan Beehan 360x1000
199
2gucci
Spottswood William Robinson 360x1000
Office of Chief Counsel 360x1000
7albion
Thomas Piketty3 360x1000
8albion'
Margaret Fuller2 360x1000
4albion
1lookingforthegoodwar
AlexRosenberg
12albion
Margaret Fuller 2 360x1000
4confidencegames
2albion
1lauber
6albion
6confidencegames
lifeinmiddlemarch2
Edmund Burke 360x1000
James Gould Cozzens 360x1000
14albion
2confidencegames
Maurice B Foley 360x1000
Susie King Taylor2 360x1000
399
11632
Mark V Holmes 360x1000
3paradise
Gilgamesh 360x1000
1lafayette
Learned Hand 360x1000
2lookingforthegoodwar
Storyparadox1
Thomas Piketty2 360x1000
1madoff
Adam Gopnik 360x1000
Margaret Fuller5 360x1000
2trap
Mary Ann Evans 360x1000
1trap
1falsewitness
Ruth Bader Ginsburg 360x1000
LillianFaderman
storyparadox2
Betty Friedan 360x1000
2transadentilist
1theleasofus
Margaret Fuller 360x1000
Maria Popova 360x1000
Anthony McCann2 360x1000
299
Susie King Taylor 360x1000
1paradide
Thomas Piketty1 360x1000
1albion
1defense
Margaret Fuller1 360x1000
Tad Friend 360x1000
10abion
1empireofpain
5confidencegames
3theleastofus
2lafayette
2theleastofus
Anthony McCann1 360x1000
Stormy Daniels 360x1000
2defense
Lafayette and Jefferson 360x1000
7confidencegames
1confidencegames
499
lifeinmiddlemarch1

Originally published on PAOO December 30, 2009 just two days before the year without an estate tax.  The end of that year promises to be a trope in many murder mysteries for years to come.

I just read in the Wall Street Journal that many people are being kept on life support in the expectation of living till the effective date of estate tax repeal.  I doubt its enough to create a power surge in the grid when all those plugs are pulled on January 1, but it is a real phenomenon.  Being one willing to go from the ridiculous to the ridiculously absurd, it occurred to me that in order to be as safe as possible, you might want to equip a hospital plane to get to a more favorable time zone.  Which way should you fly?

A lot of people would think to go East.  After all we are GMT – 5 making it later as we fly East.  That’s what a lot of people think.  Don’t be one of them.  Head west.  Only don’t stop in LA or Hawaii or even Samoa.  Get to Fiji.  Actually Tonga is good enough.  That puts you in GMT + 12, which is as good as it gets.  Kiribati is even closer, but I never even heard of that till just now.  But wait.

It doesn’t do you any good.  According to Revenue Ruling 66-85 your time of death for estate tax purposes is based on the time zone where the estate tax return is to be filed.  That’s the rule for US citizens residing in the US.  Revenue Ruling 74-24 gives a different rule for US citizens living overseas.  There is based on their domicile at time of death.  Now your domicile is not where you are at any point in time.  It is not necessarily even where you spend most of your time.  “Home is where the heart is”.  In the United States states with high-income tax rates think that nobody, in their heart, ever leaves them.  Don’t get me started on this one.

According to the latest 706 instructions all estate tax returns are filed in Cincinnati, Ohio.  That would mean that all you have to be able to do is hang on till the ball finishes dropping in Times Square.  Unless you are domiciled in the Yukon.  The commentator from whom I got these cites says that somebody from LA who dies in New York goes by West Coast time, so there is a little bit of doubt in my mind.  Maybe you should hang on till the calendar turns in Samoa to be totally free from doubt.

At any rate forget about chartering the plane.  I doubt it is practical but if you could establish domicile in Fiji between now and then you would be in the best shape possible.  Maybe send a couple of cases of Fiji water to everybody in the family.  That wouldn’t be enough, but every little bit helps.