Governor Andrew M. Cuomo’s budget bill (the “Bill”) proposes a major overhaul to the New York State tax system, including the New York State estate tax and taxation of New York trust beneficiaries. Although the Bill includes several favorable New York State estate tax reforms, such as increasing the New York State estate tax exclusion and reducing the top New York State estate tax rate, one proposal may increase estate taxes paid by New York residents by including gifts made on or after April 1, 2014 in the calculation of New York estate tax at death. As discussed in the attached memorandum, New York residents should consider making their 2014 gifts prior to April 1st.