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Results: 1-10 of 194

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

IRS issues an inconsistent ruling on whether a grantor trust can hold an IRA - Priv. Ltr. Rul. 201117042 (April 29, 2011)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • July 5 2011

In 2006, the IRS issued Private Letter Ruling 200620025 in which the IRS approved of the transfer of an Inherited IRA to a special needs trust (“SNT”) that was a grantor trust for income tax purposes

New York significantly changes its estate tax no decrease in estate tax for the wealthy

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • April 3 2014

The New York State legislature has passed, and New York Governor Andrew M. Cuomo has signed, the Executive Budget for 2014-2015, which significantly

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"

Late GST exemption allocation PLR 201313003

  • Proskauer Rose LLP
  • -
  • 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

Personal planning strategies

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 3 2014

As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent: (1) the reunification of the estate and

U.S. government sues estate and donees of J. Howard Marshall II for unpaid gift taxes

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 5 2010

The U.S. government is suing the estate and donees of J. Howard Marshall for a combined $85 million of unpaid gift and GST taxes

Income tax is payable on proceeds from surrender of a life insurance policy used to repay a loan against the policy

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2014

In a recent income tax case, the Tax Court affirmed the principal that the proceeds received from surrender of an insurance policy in excess of the

Nassau Surrogate's Court issues opinion on decanting under New York EPTL 10-6.6

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 12 2013

With In Re Kroll, 971 N.Y.S.2d 863, the Nassau Surrogate Court has issued what may be the first opinion dealing with the amended decanting statute

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