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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

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

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

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

2014 estate, gift and GST tax update: what this means for your current will, revocable trust and estate plan

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 19 2013

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

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

Chief Counsel Advice Memorandum 201208026 (9282011)

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

In a recently released Memorandum, the IRS Office of Chief Counsel concludes that contributions made by Settlors to a discretionary trust for their descendants were taxable gifts, since (1) the Settlors had not retained any rights that would make the gifts incomplete and (2) the withdrawal powers granted to the beneficiaries were unenforceable in state court and thus illusory

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

Wealth management update

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • September 4 2014

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

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

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2012

The November 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.0, which is a reduction from last month's rate of 1.2