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Private letter ruling 201144040 (November 4, 2011)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2012

In PLR 201144040, the IRS waived the 60-day deadline for a rollover where the plan administrator gave the participant incorrect tax information

Private Letter Ruling 201245004

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • February 12 2013

The IRS ruled that the surviving spouse could disclaim her interest in an Individual Retirement Account ("IRA") even though she had received

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"

IRS issues Revenue Ruling 2011-28

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • January 9 2012

On December 5, 2011, the IRS issued Revenue Ruling 2011-28, holding that a grantor's retention of the power, exercisable in a non-fiduciary capacity, to acquire a life insurance policy held in a trust by substituting other assets of equal value will not cause inclusion of the policy in the grantor's gross estate under IRC Section 2042, as long as certain guidelines are met

Estate of Thouron v. United States, E.D. Pa., no. 2:11-CS-04058 (11082012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 7 2012

The U.S. District Court for the District of Pennsylvania held that relying on the advice of a tax attorney was not reasonable cause for the late payment of estate taxes

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

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

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
  • -
  • USA
  • -
  • 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

General explanations of the administration's fiscal year 2013 revenue proposals (February 2012)

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

Each year, the U.S. Department of the Treasury issues a report setting forth the revenue proposals of the current presidential administration

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