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Recharacterizing Roth IRA conversions

Proskauer Rose LLP
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USA
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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"

New York State changes personal income tax rates

Proskauer Rose LLP
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USA
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February 2 2012

New York has modified the personal income tax rate schedule for tax years 2012 through 2014

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

PLR 201011036 (Dec. 14, 2009)

Proskauer Rose LLP
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USA
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June 7 2010

In this Private Letter Ruling request, the IRS held that the 10 early distribution penalty would not apply to taxpayer's withdrawals from his IRA because of taxpayer's disability

IRS issues Notice 2011-101

Proskauer Rose LLP
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USA
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February 2 2012

In Notice 2011-101, the IRS announced that it is studying the tax implications of "decantings" when there is a change in the beneficial interests in a trust

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

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”

Estate of Fujishima (Tax Court memorandum, January 9, 2012)

Proskauer Rose LLP
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USA
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March 6 2012

The Tax Court held that a decedent, not his mother, was the owner of two life insurance policies on his life

8th Circuit finds limited partnership’s transfer restrictions disregarded when valuing stock for gift tax purposes - Holman v. Commissioner, 2010 WL 1331270 (April 7, 2010)

Proskauer Rose LLP
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USA
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May 7 2010

The 8th Circuit, in affirming the Tax Court, found that a limited partnership created by a couple to hold Dell stock in trust for their children could not claim that the partnership's transfer restrictions constituted a bona fide business arrangement

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