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Results: 11-20 of 142

Court rescinds nonqualified disclaimer and denies gift tax liability

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

In this case, a disclaimant's parents set up Qualified Personal Resident Trusts ("QPRTs") that passed to the disclaimant, Craig, and his sister after the QPRT terms expired

Federal exclusion from gift, estate and generation-skipping transfer taxes increases to $5,340,000 in 2014

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 1 2013

In Revenue Ruling 2013-35, the IRS announced certain inflation adjustments to tax exemptions and deductions. The IRS increased the basic exclusion

Reading the IRS Q&A on net investment income tax with a focus on estates and trusts

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

On November 27, 2013, the Internal Revenue Service updated the series of Questions and Answers (the Q&A) explaining the basics of the new 3.8 percent

Former trustee of private foundation found not to be a "disqualified person" for the purpose of subsequent sale to foundation - Private Letter Ruling 201130008 (July 29, 2011)

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

In PLR 200130008, a former trustee of a private foundation, who was also the spouse of another former trustee of the private foundation, was determined not to be a disqualified person under IRC 4941(a) upon her and spouse's resignations as trustees

Keller v. United States, 5th Cir., No. 10-41311 (092512)

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

In Keller, the Fifth Circuit Court of Appeals ruled that an estate was entitled to an estate tax refund for the discounted value of a family limited partnership ("FLP") that was created during the decedent's lifetime but not fully funded until after the decedent's death

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

Trust cannot claim charitable deduction for fair market value of appreciated property donated to charity, despite fact that property was purchased with trust gross income

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 6 2010

In Chief Counsel Advice 201042023 (10222010), IRS has held that a trust cannot claim an income tax charitable deduction for the fair market value of appreciated property donated to charity, despite the fact that the property was purchased with the trust's gross income from prior years and was traceable to that income

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

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