Levin College of Law

Grayson McCouch

Clarence TeSelle Professor
Professor of Law

Mailing Address:
Box #117625 Gainesville, FL 32611

(352) 273-0991


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.

Professional Activities

  • University of Florida: Joined College of Law faculty as Professor in 2013;
  • Previous Academic Experience: Professor, University of San Diego School of Law (2001-2013); Professor, University of Miami School of Law (1995-2001); Associate Professor, University of Miami School of Law (1990-1991, 1992-1995); Associate Professor, University of Missouri – Columbia School of Law (1991-1992).
  • Government Service: Law Clerk, Judge Hugh H. Bownes, U.S. Court of Appeals for the First Circuit (1983-1984).
  • Private Practice: Sullivan & Worcester (Boston, MA, 1984-1986); Dorsey & Whitney (Minneapolis, MN, 1986-1990).
  • Professional Associations: American Law Institute.


Trusts & Estates - LAW 6930
  • Topics covered include intestate succession; family protection; execution and revocation of wills; ademption and lapse; gifts; and creation, revocation, modification and termination of trusts.
Taxation Of Gratuitous Transfers - LAW 6620
  • In addition to the income tax, taxes are imposed upon the transfer of money or other property by gift, at death, and by certain “generation skipping transfers.” This course explores each of these categories of taxes on gratuitous transfers of wealth, the interrelationships with each other, and their role in estate planning. Prerequisite: Income Taxation or permission from instructor Highly Recommended: Trusts and 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]


  • “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]