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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

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

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

April interest rates remain steady for GRATs and split interest charitable trusts and increase slightly for sales to defective grantor trusts and intra-family loans

Proskauer Rose LLP
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USA
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April 16 2010

The April applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3

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

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

Proskauer Rose LLP
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USA
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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

Federal district court finds transfer of interests in LLC to children does not qualify for the annual gift tax exclusion Fisher v. Commissioner, No. 1:08-CV-00908 (March 11, 2010)

Proskauer Rose LLP
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USA
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May 7 2010

A U.S. District Court in Indiana found the transfer of interests in a LLC to children did not qualify for the annual gift tax exclusion because the interests were considered “future” rather than “present” interests in property due to operating agreement restrictions on the children’s rights relating to the property

November interest rates remain the same for GRATs but decline for sales to defective grantor trusts, and intra-family loans

Proskauer Rose LLP
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USA
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November 5 2010

The November applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2

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

Court limits amount that surviving spouse was entitled to claim for tax on prior transfers under 2013

Proskauer Rose LLP
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USA
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November 5 2010

This case involves credits for tax on prior transfers under IRC 2013

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