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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

Haiti earthquake relief donations made before March 1, 2010 may be deducted on 2009 returns

Proskauer Rose LLP
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USA
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March 10 2010

On January 22, 2010, President Obama signed into law a provision which allows taxpayers to claim a charitable deduction in tax year 2009 for donations made after January 11, 2010 and before March 1, 2010 for the relief of victims of the Haiti earthquake

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

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

Using charitable giving techniques to offset income tax from Roth IRA conversions

Proskauer Rose LLP
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USA
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October 15 2010

In our June 2009 issue of Personal Planning Strategies, we explained that, beginning in 2010, all taxpayers, regardless of their income levels, will be eligible to take advantage of the opportunity to convert some or all of their traditional individual retirement accounts or other qualified retirement plans ("IRAs") to one or more Roth IRAs

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

Federal district court finds promoter of “Aegis” system of “trusts” guilty of conspiracy to defraud and aiding the filing of a false tax return

Proskauer Rose LLP
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USA
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April 16 2010

The defendant in Wasson was found guilty of conspiracy to defraud and of aiding in the filing of a false tax return

Step transaction doctrine applies to aggregate gifts and sales to trusts

Proskauer Rose LLP
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USA
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July 1 2010

In Pierre v. Commissioner, T.C. Memo 2010-106 (May 13, 2010), the Tax Court held that the step transaction doctrine applied to collapse the taxpayer's gifts and sales of LLC membership interests to trusts

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

Proskauer Rose LLP
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USA
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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

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