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Results: 1-10 of 88

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

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

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

Use it or lose it - increased gift and GST exemption amounts expire on 123112

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • September 10 2012

On December 17, 2010, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "2010 Act") was signed into law, making significant modifications to the estate, gift and generation-skipping transfer ("GST") taxes

Recharacterizing Roth IRA conversions

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

Beginning in 2010, many of our clients became eligible for the first time to convert their traditional individual retirement accounts or other qualified retirement plans ("Traditional IRAs") to Roth individual retirement accounts ("Roth IRAs") as a result of changes enacted under the Tax Increase Prevention and Reconciliation Act of 2005 ("TIPRA"

No charitable contribution deduction for donation of house to local fire department where value of demolition services exceeded value of property

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

In Theodore R. Rolfs, et ux. V. Comm’r, 135 T.C. No. 24 (1142010), the Tax Court denied a charitable contribution deduction for donation of a house to the local fire department where the value of the demolition services that the taxpayer would receive exceeded the value of the donated property

Decedent had no ownership interest in companies despite his involvement in the business

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • July 1 2010

In Estate of Fortunato v. Commissioner, T.C. Memo 2010-105 (May 12, 2010), the Tax Court ruled that the decedent had no ownership interest in various companies despite his involvement in the operation of the companies

Private letter ruling 201203033 (january 20, 2012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • March 6 2012

In PLR 201203033, the IRS ruled that a trust qualified as a designated beneficiary after a trust beneficiary released certain portions of a power of appointment

IRS extends interim relief to trusts and estates on investment advisory costs - Notice 2010-32

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • May 7 2010

The IRS recently issued Notice 2010-32, which extends for another year interim relief for trusts and estates on the treatment of investment advisory costs subject to the 2 floor under 67(a), so that taxpayers will not be required to determine the portion of a bundled fiduciary fee that is subject to the 2 floor for any taxable year beginning before January 1, 2010

IRS Notice 2012-21 (352012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • April 2 2012

In order for a surviving spouse to retain use of a deceased spouse's unused estate tax exemption, he or she must make a portability election on a timely filed federal estate tax return for the deceased spouse, even if no federal return needs to be filed because the decedent's assets were below his or her remaining federal estate tax exemption amount