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Results: 1-10 of 130

House votes to amend GRAT rules

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 26 2010

On March 24, 2010, the House of Representatives approved the Small Business and Infrastructure Jobs Tax Act of 2010 (H.R. 4849) (the “SBIJT Act”), which provides in part for changes to the rules governing grantor retained annuity trusts (“GRATs”) which would require all new GRATs to have a minimum ten-year term

Private letter ruling 201144040 (November 4, 2011)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2012

In PLR 201144040, the IRS waived the 60-day deadline for a rollover where the plan administrator gave the participant incorrect tax information

Recharacterizing Roth IRA conversions

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 15 2011

Beginning in 2010, many of our clients became eligible for the first time to convert their traditional individual retirement accounts or other qualified retirement plans ("Traditional IRAs") to Roth individual retirement accounts ("Roth IRAs") as a result of changes enacted under the Tax Increase Prevention and Reconciliation Act of 2005 ("TIPRA"

IRS issues Revenue Ruling 2011-28

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2012

On December 5, 2011, the IRS issued Revenue Ruling 2011-28, holding that a grantor's retention of the power, exercisable in a non-fiduciary capacity, to acquire a life insurance policy held in a trust by substituting other assets of equal value will not cause inclusion of the policy in the grantor's gross estate under IRC Section 2042, as long as certain guidelines are met

Private letter ruling 201203033 (january 20, 2012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 6 2012

In PLR 201203033, the IRS ruled that a trust qualified as a designated beneficiary after a trust beneficiary released certain portions of a power of appointment

Crummey withdrawal notices recommended practices

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • September 10 2012

Under current tax law, an individual is entitled to make gifts of up to $13,000 per donee per year without being subject to gift tax

Homestead exemption allowed for separated (but not divorced) taxpayer

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 6 2010

In Wells v. Haldeos, Fla. Dist. Ct. App., 2nd Dist., Dkt. No. 2D09-4250 (10222010), an appeal by the property appraiser of Pasco County, Florida of a final judgment in favor of the taxpayer, the Florida District Court of Appeals for the 2nd Circuit held that a separated (but not divorced) taxpayer was eligible to receive a homestead exemption for his property in Florida despite the fact that his wife receives a residency-based property tax exemption on a separate property in New York

No estate tax apportionment against payable on death accounts

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • July 1 2010

In Estate of Sheppard v. Schleis, 2010 WI 32 (Wis. May 4, 2010), the Wisconsin Supreme Court ruled that, in the absence of any tax apportionment directions by the decedent, a beneficiary of a payable-on-death account is not liable for any estate tax imposed on the decedent's estate

Tax court finds transfer of an interest in a limited partnership and timberland to an FLP was not includible in the decedent’s gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 10 2010

This Tax Court decision provides another Section 2036 victory for the taxpayer by holding that assets transferred to an FLP were not includible in the decedent's gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration

General explanations of the administration's fiscal year 2013 revenue proposals (February 2012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • April 2 2012

Each year, the U.S. Department of the Treasury issues a report setting forth the revenue proposals of the current presidential administration