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Results: 11-20 of 136

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

Proposed Treas. Reg. 1.67-4

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2011

Treasury has issued new proposed Regulations in connection with what costs incurred by estates or non-grantor trusts are subject to the 2 floor for miscellaneous deductions under I.R.C. 67(a

The Tax Court holds, in a summary judgment ruling, that the Beneficiaries of gifts who are obligated to pay any potential estate tax liability arising from the gifts may decrease the value of the gift by the actuarial value of that obligation

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

In Steinberg v. Commissioner, 141 T.C. No. 8 (September 30, 2013), a mother (the "Parent") gave cash and securities to her daughters (the

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

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

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 8 2013

The March 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4, which is a slight increase from

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

Estate of Turner v. Comm’r, T.C. Memo 2011-209 (Aug. 30, 2011)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2011

The Tax Court has held that (a) assets contributed to a family limited partnership (“FLP”) were includable in a decedent’s gross estate under section 2036(a) of the Internal Revenue Code of 1986, as amended (“I.R.C.”), and (b) premiums paid directly to a carrier on behalf of an insurance trust qualified for the annual gift tax exclusion as present interest gifts

Wealth management update

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 13 2014

The March 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.2, which is a 0.2 decrease from last

Disclaimer not qualified where disclaimed property passed to disclaimant by intestacy

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

In Estate of Tatum, Jr. v. U.S., 106 AFTR 2d 2010-6556 (S.D. Miss. 1062010), the Southern District of Mississippi held that a disclaimer was not qualified where the disclaimed property passed to the disclaimant by intestacy

Liability of a trust protector at issue in McLean v. Ponder

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

The Missouri Court of Appeals recently issued an opinion involving the liability of a Trust Protector for not exercising his powers to remove and