Levin College of Law

Grayson McCouch

Clarence TeSelle Professor
Professor of Law


Estates  • Taxation of Estates & Trusts  • Trusts  • Wills  • 


Professor Grayson M.P. McCouch is the Clarence TeSelle Professor and Professor of Law at the University of Florida. He teaches primarily in the areas of trusts and estates, estate and gift taxation, and estate planning. Before teaching at UF, McCouch clerked for Judge Hugh Bownes on the U.S. Court of Appeals for the First Circuit, practiced law with firms in Boston and Minneapolis, and served as a member of the law faculty at the University of Miami and the University of San Diego. McCouch has published numerous books and articles, reflecting a wide range of scholarly interests including estate and gift taxation, inheritance law, social security, retirement savings policy, and tax shelters. McCouch is a co-author of leading casebooks on gratuitous transfers and federal estate and gift taxation. He is a member of the American Law Institute. He earned his J.D. degree from Stanford University and his LL.M. in Taxation from Boston University.


LL.M. (Taxation), Boston University
J.D., Stanford University
A.B., Harvard University

Teaching and Scholarship

Estates and Trusts; Taxation of Gratuitous Transfers; Estate Planning.


  • Advanced Trusts and Estates
  • Taxation of Gratuitous Transfers
  • Trusts & Estates



  • Federal Income Taxation of Estates, Trusts, and Beneficiaries, 2d ed. (West, 2020) [Link]
  • Federal Estate and Gift Taxation, 12th ed. (West, 2020) (with Bittker and Clark) [Link]
  • Federal Estate and Gift Taxation 9th ed. (West, 2020) (with McNulty) [Link]
  •  Introduction to Estate Planning 7th ed. (West, 2019) (with Lynn) [Link]
  • Gratuitous Transfers, 7th ed. (West, 2018) (with Ascher) [Link]


  • Connelly’s Conundrum: Insurance Proceeds and Stock Redemptions, 182 Tax Notes 2199 (2024).
  • Perpetual Generation-Skipping Trusts, 58 Real Prop., Tr. & Est. L.J. 167 (2023).
  • Custodianships, Trusts, and Guardianships, 40 Va. Tax Rev. 419 475 (2021).
  • “Adversity, Inconsistency, and the Incomplete Nongrantor Trust,” 39 Va. Tax Rev. 419 (2020)
  • “Post-Marital Income Shifting and the End of Alimony Trusts,” 54 Real Prop., Tr. & Est. L.J. 179 (2019)
  • “Revocable Trusts and Fiduciary Accountability,” 26 Elder L.J. 1 (2018)
  • “Another Perspective on Testamentary Arbitration,” 68 Fla. L. Rev. Forum 68 (2016)
  • “Sham Partnerships and Equivocal Transactions” (with Karen Burke), 69 Tax Law. 625 (2016)
  • “Codifying Castle Harbour” (with Karen Burke), 150 Tax Notes 109 (2016) [SSRN]
  • “The Moving Target of Tax Reform” (with Karen Burke), 93 N.C. L. Rev.  649 (2015) [SSRN]
  • “Woods: A Path Through the Penalty Maze,” (with Karen Burke) 142 Tax Notes 829 (2014) [SSRN]
  • “Who Killed the Rule Against Perpetuities?” 40 Pepp. L. Rev. 1291 (2013) [SSRN]
  • “Reflections on Penalty Jurisdiction in Tigers Eye” (with Karen Burke), 136 Tax Notes 1581 (2012)
  • “Illusory Partnership Interests and the Anti-Antiabuse Rule” (with Karen Burke), 132 Tax Notes 813 (2011) [SSRN]
  • The Empty Promise of Estate Tax Repeal, 28 Va. Tax Rev. 369 (2008) [SSRN]
  • COBRA Strikes Back: Anatomy of a Tax Shelter, 62 Tax Law. 59 (2008) (with Burke) [SSRN]