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Results: 1-10 of 142

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

IRS issues an inconsistent ruling on whether a grantor trust can hold an IRA - Priv. Ltr. Rul. 201117042 (April 29, 2011)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • July 5 2011

In 2006, the IRS issued Private Letter Ruling 200620025 in which the IRS approved of the transfer of an Inherited IRA to a special needs trust (“SNT”) that was a grantor trust for income tax purposes

New York significantly changes its estate tax no decrease in estate tax for the wealthy

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • April 3 2014

The New York State legislature has passed, and New York Governor Andrew M. Cuomo has signed, the Executive Budget for 2014-2015, which significantly

Personal planning strategies

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 3 2014

As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent: (1) the reunification of the estate and

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

Nassau Surrogate's Court issues opinion on decanting under New York EPTL 10-6.6

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • December 12 2013

With In Re Kroll, 971 N.Y.S.2d 863, the Nassau Surrogate Court has issued what may be the first opinion dealing with the amended decanting statute

Favorable "DING trust" rulings PLRs 201310002 201310006

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • 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

Chief Counsel Advice Memorandum 201208026 (9282011)

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • April 2 2012

In a recently released Memorandum, the IRS Office of Chief Counsel concludes that contributions made by Settlors to a discretionary trust for their descendants were taxable gifts, since (1) the Settlors had not retained any rights that would make the gifts incomplete and (2) the withdrawal powers granted to the beneficiaries were unenforceable in state court and thus illusory

No estate tax apportionment against payable on death accounts

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • July 1 2010

In Estate of Sheppard v. Schleis, 2010 WI 32 (Wis. May 4, 2010), the Wisconsin Supreme Court ruled that, in the absence of any tax apportionment directions by the decedent, a beneficiary of a payable-on-death account is not liable for any estate tax imposed on the decedent's estate

Court rescinds nonqualified disclaimer and denies gift tax liability

  • Proskauer Rose LLP
  • -
  • USA
  • -
  • November 5 2010

In this case, a disclaimant's parents set up Qualified Personal Resident Trusts ("QPRTs") that passed to the disclaimant, Craig, and his sister after the QPRT terms expired