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We didn't (quite) fall off the cliff, but we still have to clean up the mess!

Proskauer Rose LLP
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USA
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January 8 2013

When the clock struck midnight on December 31, 2012, estate planning practitioners said "good night" to an unprecedented period of working with clients to

Estate of Giovacchini v. Commissioner, T.C. Memo 2013-27

Proskauer Rose LLP
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USA
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March 8 2013

The Tax Court redetermined values for estate and gift tax purposes of a large parcel of more than 2,500 acres of land near Lake Tahoe, California

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

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
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USA
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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

Estate is not entitled to an estate tax charitable deduction for the amount received by a charitable trust pursuant to a settlement agreement

Proskauer Rose LLP
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USA
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March 10 2010

The IRS held that an estate was not entitled to an estate tax charitable deduction for the amount paid to a charitable trust pursuant to a settlement agreement

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

April interest rates remain steady for GRATs and split interest charitable trusts and increase slightly for sales to defective grantor trusts and intra-family loans

Proskauer Rose LLP
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USA
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April 16 2010

The April applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3

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

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

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