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

Proskauer Rose LLP
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USA
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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

Estate of Koons v. Commissioner, T.C. Memo 2013-94

Proskauer Rose LLP
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USA
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June 3 2013

The Tax Court adopted the IRS's valuation of a revocable trust's interest in a business with mostly liquid assets, finding that the taxpayer's

Knappe v. U.S., 111 AFTR-2d 2013-1531 (9th Cir.)

Proskauer Rose LLP
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USA
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June 3 2013

The executor relied on the advice of his accountant that the time period for both extending the time to file an estate tax return as well as the time

U.S. v. Blake, E.D.N.Y, No. 12-cv-02577

Proskauer Rose LLP
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USA
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June 3 2013

The U.S. District Court for the Eastern District of New York abstained from jurisdiction in a claim by the government to collect estate taxes because

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

Proskauer Rose LLP
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USA
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June 3 2013

The June 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.2, which is a slight decrease from April's rate

Tax Court holds that trusteebeneficiary's power to invade trust principal for her "welfare" is limited by an ascertainable standard and trust principal not includible in her estate under IRC 2041(b)(1)(a) estate of Ann R. Chancellor, et al. v. Commiss

Proskauer Rose LLP
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USA
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September 14 2011

Frequently, trust agreements ensure that the principal invasion power held by a trustee who is also a beneficiary is limited to distributions for the beneficiary's "health, education, maintenance and support"

U.S. government sues estate and donees of J. Howard Marshall II for unpaid gift taxes

Proskauer Rose LLP
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USA
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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

Crummey withdrawal notices recommended practices

Proskauer Rose LLP
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USA
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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

Favorable "DING trust" rulings PLRs 201310002 201310006

Proskauer Rose LLP
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USA
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May 1 2013

In five related rulings, the IRS issued favorable holdings addressing the income and gift tax consequences of so-called "DING trusts." The acronym

Late GST exemption allocation PLR 201313003

Proskauer Rose LLP
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USA
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May 1 2013

The IRS exercised its discretion to allow a taxpayer to make a late allocation of GST exemption. Over a six-year period, the taxpayer made transfers

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