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Results: 11-20 of 142

Sale of assets for fair market value between a marital trust and a nonmarital trust to settle a dispute between beneficiaries and trustees of the trusts was neither a taxable gift nor a transfer of an income interest in a QTIP Priv. Ltr. Rul. 201119003

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

In this private letter ruling, the issue was whether the transfer of assets for fair market value between a marital trust and a nonmarital trust resulted in a taxable gift or a disposition of an income interest in qualified terminable interest property (“QTIP”

Rush University Medical Center v. Sessions, 2012 IL 112906 (09202012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 7 2012

In Rush, an estate tried to enforce a self-settled spendthrift trust without a state statute protecting it

New York expands EPTL 10-6.6 to further liberalize trust "decanting"

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • September 14 2011

On August, 17, 2011, New York Governor Andrew Cuomo signed into law Bill A8297 which expands the State's decanting statute (Estates, Powers and Trust Law 10-6.6

IRS issues Revenue Procedure 2013-15

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

In Revenue Procedure 2013-15, the IRS announced the 2013 inflation adjustments, including the income tax rate schedules, and other tax changes

Delaware Supreme Court offers guidance on when Delaware law applies to a trust originally subject to another state's law

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

In a series of three opinions, all relating to trusts created for the benefit of members of the Peierls Family, the Delaware Supreme Court has

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
  • -
  • USA
  • -
  • 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"

IRS extends interim relief to trusts and estates on investment advisory costs - Notice 2010-32

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

The IRS recently issued Notice 2010-32, which extends for another year interim relief for trusts and estates on the treatment of investment advisory costs subject to the 2 floor under 67(a), so that taxpayers will not be required to determine the portion of a bundled fiduciary fee that is subject to the 2 floor for any taxable year beginning before January 1, 2010

August interest rates for grats, sales to defective grantor trusts, intra-family loans and split interest charitable trusts continue decline

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

The August applicable federal rate (“AFR”) for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.2

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

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • 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

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