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IRS announces it is reopening the offshore voluntary disclosure program

Proskauer Rose LLP
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USA
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February 2 2012

The IRS announced it is reopening the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes

Hirchert Family Trust v. Johnee Ann Alle Hirchert (District Court of Appeal of Florida, Fifth District, June 17, 2011)

Proskauer Rose LLP
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USA
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September 14 2011

The District Court of Appeal of Florida upheld an exception to the Florida homestead exemption in a case where a trusteedeceased husband of the defendant breached his fiduciary duty as trustee in California, and the defendant later used the proceeds resulting from this breach to purchase real property in Florida

Chief Counsel Advice Memorandum 201208026 (9282011)

Proskauer Rose LLP
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USA
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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

Revenue procedure 2011-48 (October 14, 2011)

Proskauer Rose LLP
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USA
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December 5 2011

The IRS has issued guidance on the procedure for the filing and resolution of a Protective Claim for Refund of estate tax that is based on a deduction for a claim or expense under section 2053 of the Internal Revenue Code (Code

The Tax Court disallows charitable deductions and imposes accuracy-related penalties for failure to substantiate equipment donations

Proskauer Rose LLP
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USA
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May 7 2010

The Tax Court disallowed a couple's charitable deductions and imposed accuracy-related penalties after finding they did not properly substantiate the contributions or provide contemporaneous written acknowledgements of their medical equipment donations

IRS alerts taxpayers that it intends to issue guidance under Section 2511(c)

Proskauer Rose LLP
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USA
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March 10 2010

Section 2511(c) provides that, notwithstanding any other provision of Section 2511 and except as provided in the regulations, a transfer in trust is treated as a transfer of property by gift unless the trust is treated as wholly owned by the donor or the donor's spouse under the grantor trust provisions

Federal Court of Claims holds that primary executor of estate was not entitled to reissuance of $10 million refund when check was previously issued to and negotiated by an ancillary executor

Proskauer Rose LLP
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USA
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April 16 2010

The Federal Court of Claims recently denied a U.S. executor’s claim for a federal tax refund when the IRS had previously issued a refund check to a non-U.S. ancillary executor

Estate not entitled to discount the value of three marital trusts for claims by ESOP members against the marital trusts’ assets Estate of Foster v. Comm’r, T.C. Memo 2011-95 (4282011)

Proskauer Rose LLP
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USA
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July 5 2011

In Foster, the Tax Court considered the following: (1) whether an estate was entitled to discount the value of assets in three marital trusts due to the potential for litigation; and (2) whether assets in the marital trusts could be discounted for lack of control over and lack of marketability of the marital trusts’ assets

Loan interest paid by trust held non-deductible in decedent’s estate because it was unnecessary

Proskauer Rose LLP
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USA
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November 5 2010

After Decedent’s death, his trust borrowed $1.5 million from Decedent’s Foundation to pay his estate tax liabilities (aka a “Graegin” loan

Electing out of the application of the estate tax and allocating basis step-up for 2010 decedents

Proskauer Rose LLP
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USA
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August 9 2011

The legislation enacted in December 2010 retroactively reinstated the federal Estate tax for 2010 decedents but allows an applicable Executor to “opt out” of the Estate tax regime by making a “Section 1022 Election”

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