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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

Creating a "GRAT": heads you win, tails you break even

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • September 1 2011

Creating a grantor retained annuity trust (commonly referred to as a "GRAT") is a relatively simple way to transfer property to your children at virtually no gift tax cost

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

New York considers raising estate tax exemption, reinstating gift tax, eliminating GST tax and closing the resident trust loophole

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2014

On November 14, 2013, the New York State Tax Reform and Fairness Commission presented its final report to the Governor containing various

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

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • 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

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

Estate of Thouron v. United States, E.D. Pa., no. 2:11-CS-04058 (11082012)

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

The U.S. District Court for the District of Pennsylvania held that relying on the advice of a tax attorney was not reasonable cause for the late payment of estate taxes

Tax court finds transfer of an interest in a limited partnership and timberland to an FLP was not includible in the decedent’s gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 10 2010

This Tax Court decision provides another Section 2036 victory for the taxpayer by holding that assets transferred to an FLP were not includible in the decedent's gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration

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