One of the remarkable changes to the 2010 tax law increases the amount a taxpayer may gift on a tax-free basis from $1 million to $5,120,000 ($10,240,000 per couple) for 2012, more than five times greater than any gift tax exclusion previously offered. This exclusion is only available until the end of 2012 and, as of the present time, there has been no discussion in Congress of what it will be willing to do, if anything, to alter or ameliorate the reversion.