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We didn't (quite) fall off the cliff, but we still have to clean up the mess!

Proskauer Rose LLP
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USA
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January 8 2013

When the clock struck midnight on December 31, 2012, estate planning practitioners said "good night" to an unprecedented period of working with clients to

Estate of Giovacchini v. Commissioner, T.C. Memo 2013-27

Proskauer Rose LLP
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USA
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March 8 2013

The Tax Court redetermined values for estate and gift tax purposes of a large parcel of more than 2,500 acres of land near Lake Tahoe, California

Estate of Kite v. Commissioner, T.C. Memo 2013-43

Proskauer Rose LLP
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USA
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March 8 2013

The Tax Court held that a surviving spouse's sale of substantial entity interests to trusts for her children in exchange for a 10-year deferred

New Form 1041, U.S. Income Tax Return for Estates and Trusts for 2012, and instructions released

Proskauer Rose LLP
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USA
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March 8 2013

The IRS has released a final version of the Form 1041, U.S. Income Tax Return for Estates and Trusts for 2012, and the corresponding instructions

PLR 201303003

Proskauer Rose LLP
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USA
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March 8 2013

The IRS privately ruled that a marital trust that qualified as a QTIP trust under Internal Revenue Code Section 2056(b)(7) would still qualify as

March 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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March 8 2013

The March 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4, which is a slight increase from

IRS considering change in method used to determine AFRs

Proskauer Rose LLP
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USA
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March 8 2013

The IRS has announced that it is considering changes to the methodology used to determine the adjusted applicable federal rates (AFRs) and the

IRS releases directive on total return swaps used to avoid dividend withholding tax

Proskauer Rose LLP
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USA
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March 3 2010

On January 14, 2010, the IRS issued an industry directive (the “Directive”) to its field examiners providing guidance on examining total return swaps that may have been executed in order to avoid tax with respect to U.S. source dividends paid to foreign persons

Proposed regulations exempt taxpayers from FBAR reporting for interests in offshore private equity and hedge funds until further guidance is issued

Proskauer Rose LLP
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USA
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March 3 2010

On February 26, 2010, the Treasury Department published long-awaited, revised proposed regulations clarifying which taxpayers will be required to file the Report of Foreign Bank and Financial Accounts, Form TD F 90-22

IRS establishes guidelines to fix deferred compensation plan document defects under Code Section 409A

Proskauer Rose LLP
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USA
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March 3 2010

On January 5, 2010, the IRS issued Notice 2010-6 (the "IRS Notice"), which establishes a correction program for certain inadvertent instances of documentary noncompliance involving deferred compensation arrangements subject to Section 409A of the Internal Revenue Code ("409A"

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