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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

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

IRS seeks comment on rules for estate tax return filing extensions

Proskauer Rose LLP
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USA
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March 8 2013

The Internal Revenue Service is seeking public comment on final regulations governing the extension of time to file estate tax returns, which allow

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

IRS issues Revenue Procedure 2013-15

Proskauer Rose LLP
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USA
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February 12 2013

In Revenue Procedure 2013-15, the IRS announced the 2013 inflation adjustments, including the income tax rate schedules, and other tax changes

Estate of Nancy P. Young v. United States (D. Mass., No. 1:11-cv-11829-RWZ, 121712)

Proskauer Rose LLP
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USA
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February 12 2013

In Estate of Nancy P. Young v. United States, the District Court upheld a latefiling penalty against an estate whose accountants advised it to file

Private Letter Ruling 201245004

Proskauer Rose LLP
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USA
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February 12 2013

The IRS ruled that the surviving spouse could disclaim her interest in an Individual Retirement Account ("IRA") even though she had received

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 Bates v. Commissioner, T.C. Memo. 2012-314, November 7, 2012

Proskauer Rose LLP
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USA
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December 7 2012

The Tax Court ruled that the cost of settlement could not be deducted as an administrative expense on an estate tax return, because the claim was for a beneficiary's distributive share and not for a creditor's claim against the estate