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Favorable "DING trust" rulings PLRs 201310002 201310006

Proskauer Rose LLP
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USA
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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

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

Proskauer Rose LLP
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USA
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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

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
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USA
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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"

Crummey withdrawal notices recommended practices

Proskauer Rose LLP
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USA
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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

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

Proskauer Rose LLP
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USA
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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

Estate of Kite v. Commissioner, T.C. Memo 2013-43

Proskauer Rose LLP
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USA
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March 8 2013

The Tax Court held that a surviving spouse's sale of substantial entity interests to trusts for her children in exchange for a 10-year deferred

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

Proskauer Rose LLP
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USA
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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

U.S. government sues estate and donees of J. Howard Marshall II for unpaid gift taxes

Proskauer Rose LLP
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USA
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November 5 2010

The U.S. government is suing the estate and donees of J. Howard Marshall for a combined $85 million of unpaid gift and GST taxes

IRS announces notice and proposed regulations regarding Form TD F 90.22-1 Report of Foreign Bank and Financial Accounts (the FBAR) Notice 201023;

Proskauer Rose LLP
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USA
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April 16 2010

The IRS has recently announced further guidance in the area of reporting non-U.S. bank and financial accounts

Court rescinds nonqualified disclaimer and denies gift tax liability

Proskauer Rose LLP
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USA
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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

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