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Results: 11-20 of 138

Favorable "DING trust" rulings PLRs 201310002 201310006

  • Proskauer Rose LLP
  • -
  • 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

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

Now is the time to take advantage of changes to the federal gift and generation-skipping transfer taxes in 2010

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • October 15 2010

Two changes to the Federal wealth transfer system that were enacted pursuant to the Economic Growth and Tax Relief Reconciliation Act of 2001 (the "2001 Act") during President Bush's first year in office create, at least in the absence of retroactive legislation, a favorable environment in 2010 for gift planning

Electing out of the application of the estate tax and allocating basis step-up for 2010 decedents

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • August 9 2011

The legislation enacted in December 2010 retroactively reinstated the federal Estate tax for 2010 decedents but allows an applicable Executor to “opt out” of the Estate tax regime by making a “Section 1022 Election”

Use it or lose it - increased gift and GST exemption amounts expire on 123112

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

On December 17, 2010, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "2010 Act") was signed into law, making significant modifications to the estate, gift and generation-skipping transfer ("GST") taxes

6th Circuit finds regulation reasonable on generation-skipping transfer tax Estate of Timken, 2010 WL 1253627 (April 2, 2010)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • May 7 2010

The 6th Circuit found that Treasury Regulation 26.2601-1(b)(1)(v)(A), stipulating that the grandfathering exemption to the generation-skipping transfer tax (“GST”) does not apply when there is a post-statute exercise of lapse of a general power of appointment, is reasonable

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

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

The December 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.0, which is unchanged from last month

Wealth management update

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • July 23 2014

The August 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.2, the same as the 7520 rate for July. The

Adams v. Comm’r, T.C. Memo 2010-72 (April 13, 2010).

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • June 7 2010

In this case, the Tax Court held that a beneficiary was permitted to claim a mortgage interest deduction for trust property

IRS Notice 2012-21 (352012)

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

In order for a surviving spouse to retain use of a deceased spouse's unused estate tax exemption, he or she must make a portability election on a timely filed federal estate tax return for the deceased spouse, even if no federal return needs to be filed because the decedent's assets were below his or her remaining federal estate tax exemption amount