Search results

Order by most recent / most popular / relevance

Results: 1-10 of 34

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
-
USA
-
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"

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

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

California Board of Equalization to release information to IRS

Proskauer Rose LLP
-
USA
-
February 2 2012

A California district court recently ruled that the IRS can serve "John Doe" summons on the California Board of Equalization in order to obtain a list of the names of California property owners who gifted real estate to family members between 2005 and 2010

Tax Court finds taxpayers who employed Roth IRA conversion tax shelter were liable for excise tax and penalties Paschall v. Commissioner, 137 T.C. No. 2 (July 5, 2011); Swanson v. Commissioner, T.C. Memo 2011-156 (July 5, 2011)

Proskauer Rose LLP
-
USA
-
August 5 2011

In the companion cases of Paschall v. Commissioner and Swanson v. Commissioner, the Tax Court found that taxpayers who employed a Roth IRA conversion tax shelter were liable for excise taxes on account of excess contributions to the Roth IRAs and were also liable for failure to file penalties

Loan interest paid by trust held non-deductible in decedent’s estate because it was unnecessary

Proskauer Rose LLP
-
USA
-
November 5 2010

After Decedent’s death, his trust borrowed $1.5 million from Decedent’s Foundation to pay his estate tax liabilities (aka a “Graegin” loan

Estate of Fujishima (Tax Court memorandum, January 9, 2012)

Proskauer Rose LLP
-
USA
-
March 6 2012

The Tax Court held that a decedent, not his mother, was the owner of two life insurance policies on his life

8th Circuit finds limited partnership’s transfer restrictions disregarded when valuing stock for gift tax purposes - Holman v. Commissioner, 2010 WL 1331270 (April 7, 2010)

Proskauer Rose LLP
-
USA
-
May 7 2010

The 8th Circuit, in affirming the Tax Court, found that a limited partnership created by a couple to hold Dell stock in trust for their children could not claim that the partnership's transfer restrictions constituted a bona fide business arrangement

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

Federal Court of Claims holds that primary executor of estate was not entitled to reissuance of $10 million refund when check was previously issued to and negotiated by an ancillary executor

Proskauer Rose LLP
-
USA
-
April 16 2010

The Federal Court of Claims recently denied a U.S. executor’s claim for a federal tax refund when the IRS had previously issued a refund check to a non-U.S. ancillary executor

next >