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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 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

In Re: Grand Jury Subpoena, 5th Cir., No. 11-20750 (09212012)

Proskauer Rose LLP
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USA
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November 15 2012

The Fifth Circuit Court of Appeals reversed the district court's denial of the government's motion to compel production of foreign bank account records required to be kept under Treasury Department regulations by the target of a grand jury investigation (the "witness"

May 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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May 1 2013

The May 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

Keller v. United States, 5th Cir., No. 10-41311 (092512)

Proskauer Rose LLP
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USA
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November 15 2012

In Keller, the Fifth Circuit Court of Appeals ruled that an estate was entitled to an estate tax refund for the discounted value of a family limited partnership ("FLP") that was created during the decedent's lifetime but not fully funded until after the decedent's death

New Jersey Federal District Court finds that the IRS abused its discretion in disallowing extension of time to file estate tax return

Proskauer Rose LLP
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USA
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September 7 2010

In Estate of Proske v. United States, Civil Action No. 09-CV-670 (DMC) (USDC D.N.J. May 25, 2010), the New Jersey District Court found that the IRS abused its discretion in disallowing the estate an extension of time to file its Federal estate tax return

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

Hastings v. PNC Bank NA, Md. No. 109 (09272012)

Proskauer Rose LLP
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USA
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November 15 2012

The Maryland Court of Appeals holds for PNC in a suit by the beneficiaries of a testamentary trust created under the will of a Maryland resident where the beneficiaries claimed that PNC breached its fiduciary duty in requiring them to sign a release agreement arguably too favorable to PNC before distributing assets to them

New York and Florida joins sixteen other states in enacting formula clause fixes

Proskauer Rose LLP
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USA
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September 7 2010

State legislatures are catching the ball that the Federal legislature dropped in permitting the Federal estate and generation-skipping transfer ("GST") taxes to lapse in 2010

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