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Private Letter Ruling 201236022 (09112012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2012

In this PLR, the Internal Revenue Service ("IRS") ruled that amounts paid to charities from the residue of the decedent's estate pursuant to a settlement agreement qualified for the charitable deduction for federal estate tax purposes because the charities had an enforceable right under state law to receive a portion of the residuary estate due to the undue influence by the drafting attorney (who was also a beneficiary

Scaggs v. Comm'r, T.C. No. 16342-11, T.C. Memo 2012-258 (09102012)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2012

The United States Tax Court upheld the denial of a taxpayer's petition for redetermination of deficiencies and accuracy-related penalties because the taxpayer did not use a designated private delivery service

Keller v. United States, 5th Cir., No. 10-41311 (092512)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2012

In Keller, the Fifth Circuit Court of Appeals ruled that an estate was entitled to an estate tax refund for the discounted value of a family limited partnership ("FLP") that was created during the decedent's lifetime but not fully funded until after the decedent's death

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

Private letter ruling 201151003 (December 23, 2011)

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

The IRS granted a decedent's estate an extension to make the alternate valuation election where the executor of the estate relied on advice of the CPA that he hired to prepare and file the decedent's estate tax return

Internal Revenue Bulletin 2012-46 (11132012)

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

The IRS said that it does not acquiesce in the Tax Court's March ruling in Wandry v. Commissioner, despite the recent withdrawal of the government's appeal

Estate of Bates v. Commissioner, T.C. Memo. 2012-314, November 7, 2012

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

The Tax Court ruled that the cost of settlement could not be deducted as an administrative expense on an estate tax return, because the claim was for a beneficiary's distributive share and not for a creditor's claim against the estate

Rev. Proc. 2012-14 (10182012)

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

The IRS released the inflation adjustments affecting various sections of the Internal Revenue Code for 2013

November interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 15 2012

The November 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.0, which is a reduction from last month's rate of 1.2

Schwab v. Commissioner, 111 AFTR-2d 2013-667 (April 24, 2013)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • June 3 2013

The Court of Appeals for the 9th Circuit held that the "amount actually distributed" when taxpayers received ownership of life insurance policies was