In a previous post, I showed that both H.R. 4849 and H.R. 5486 would limit grantor retained annuity trusts using identical language. See On June 9, 2010, Rep. Sander Levin introduced another bill that would restrict GRATs – H.R. 5486.
I am curious: If the language reforming GRATs in H.R. 4849 and H.R. 5486 is identical, why does the JCT estimate that GRAT reform would raise $4.450 billion in H.R. 4849 and $5.297 billion in H.R. 5486? Both numbers are estimates, but one would think that the estimates should be identical. I am not an economist, so I would appreciate your thoughts on this discrepancy.
Compare the following: