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Favorable "DING trust" rulings PLRs 201310002 201310006

Proskauer Rose LLP
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USA
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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

Estate of Nancy P. Young v. United States (D. Mass., No. 1:11-cv-11829-RWZ, 121712)

Proskauer Rose LLP
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USA
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February 12 2013

In Estate of Nancy P. Young v. United States, the District Court upheld a latefiling penalty against an estate whose accountants advised it to file

Tax Court holds that trusteebeneficiary's power to invade trust principal for her "welfare" is limited by an ascertainable standard and trust principal not includible in her estate under IRC 2041(b)(1)(a) estate of Ann R. Chancellor, et al. v. Commiss

Proskauer Rose LLP
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USA
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September 14 2011

Frequently, trust agreements ensure that the principal invasion power held by a trustee who is also a beneficiary is limited to distributions for the beneficiary's "health, education, maintenance and support"

Nevada Governor signed into law S.B. 221 with an effective date of October 1, 2011, which makes Nevada’s asset protection trust laws even stronger S.B. 221, 76th Sess., Reg. Sess.

Proskauer Rose LLP
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USA
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July 5 2011

On June 4, 2011, Nevada Governor Brian Sandoval signed into law S.B. 221 with an effective date of October 1, 2011

In Re: Grand Jury Subpoena, 5th Cir., No. 11-20750 (09212012)

Proskauer Rose LLP
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USA
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November 15 2012

The Fifth Circuit Court of Appeals reversed the district court's denial of the government's motion to compel production of foreign bank account records required to be kept under Treasury Department regulations by the target of a grand jury investigation (the "witness"

Late GST exemption allocation PLR 201313003

Proskauer Rose LLP
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USA
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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

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

Proskauer Rose LLP
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USA
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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

Like-kind exchange of life insurance policies PLR 201304003

Proskauer Rose LLP
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USA
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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

No estate tax apportionment against payable on death accounts

Proskauer Rose LLP
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USA
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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

Crummey withdrawal notices recommended practices

Proskauer Rose LLP
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USA
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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

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