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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 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
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
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
IRS alerts taxpayers that it intends to issue guidance under Section 2511(c)
- Proskauer Rose LLP
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- USA
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- March 10 2010
Section 2511(c) provides that, notwithstanding any other provision of Section 2511 and except as provided in the regulations, a transfer in trust is treated as a transfer of property by gift unless the trust is treated as wholly owned by the donor or the donor's spouse under the grantor trust provisions
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
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- USA
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- 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
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- USA
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- 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
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
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- Workarea - Corporate Tax
- Workarea - Private Client & Offshore Services
- Author - Albert W Gortz
- Author - George D Karibjanian
- Author - Andrew M Katzenstein