Rather than excluding an entire pharmaceutical giant for example, which many say is impractical, limit the exclusion to the product or business unit that was the locus of the fraud.

FORBES: Fraud Shouldn't Be So Rewarding

Only gifts that exceed the limit count against the lifetime exclusion.

FORBES: After The Fiscal Cliff Deal: Estate And Gift Tax Explained

It could limit other big tax preferences for the wealthy, such as the exclusion for contributions to retirement plans.

FORBES: Mr. President, There Is A Way To Raise Taxes On The Rich Without Raising Their Rates