Favorable "DING trust" rulings – PLRs 201310002 – 201310006 *

USA - May 1 2013
In five related rulings, the IRS issued favorable holdings addressing the income and gift tax consequences of so-called "DING trusts." The acronym…

Co-authors: David Pratt, Albert W Gortz, Andrew M Katzenstein, George D Karibjanian, Mitchell M Gaswirth.

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Like-kind exchange of life insurance policies – PLR 201304003 *

USA - May 1 2013
The IRS privately ruled that the exchange by an irrevocable trust of a second-to-die life insurance policy for a new first-to-die policy would…

Co-authors: David Pratt, Albert W Gortz, Andrew M Katzenstein, George D Karibjanian, Mitchell M Gaswirth.

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Late GST exemption allocation – PLR 201313003 *

USA - May 1 2013
The IRS exercised its discretion to allow a taxpayer to make a late allocation of GST exemption. Over a six-year period, the taxpayer made transfers…

Co-authors: David Pratt, Albert W Gortz, Andrew M Katzenstein, George D Karibjanian, Mitchell M Gaswirth.

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May interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts *

USA - May 1 2013
The May § 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2%, which is a slight decrease from April's…

Co-authors: David Pratt, Albert W Gortz, Andrew M Katzenstein, George D Karibjanian, Mitchell M Gaswirth.

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Villareale v. Commissioner, T.C. Memo 2013-74 *

USA - May 1 2013
The Tax Court determined the taxpayer was not entitled to a charitable contribution deduction for contributions she made to a public charity she…

Co-authors: David Pratt, Albert W Gortz, Andrew M Katzenstein, George D Karibjanian, Mitchell M Gaswirth.

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