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Results: 1-10 of 132

Intra-family loans: a simple yet effective estate planning tool
  • Proskauer Rose LLP
  • USA
  • September 1 2011

An intra-family loan is a basic estate-planning technique which has a very low transaction cost


PLR 201011036 (Dec. 14, 2009)
  • Proskauer Rose LLP
  • USA
  • June 7 2010

In this Private Letter Ruling request, the IRS held that the 10 early distribution penalty would not apply to taxpayer's withdrawals from his IRA because of taxpayer's disability


April interest rates remain steady for GRATs and split interest charitable trusts and increase slightly for sales to defective grantor trusts and intra-family loans
  • Proskauer Rose LLP
  • USA
  • April 16 2010

The April applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3


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


IRS announces notice and proposed regulations regarding Form TD F 90.22-1 Report of Foreign Bank and Financial Accounts (the FBAR) Notice 201023;
  • Proskauer Rose LLP
  • USA
  • April 16 2010

The IRS has recently announced further guidance in the area of reporting non-U.S. bank and financial accounts


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


Use it or lose it - increased gift and GST exemption amounts expire on 123112
  • Proskauer Rose LLP
  • USA
  • September 10 2012

On December 17, 2010, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "2010 Act") was signed into law, making significant modifications to the estate, gift and generation-skipping transfer ("GST") taxes


Income tax deductions for charitable donations may be denied without a qualified appraisal Mohamed v. Commissioner, T.C. Memo 2012-152
  • Proskauer Rose LLP
  • USA
  • September 10 2012

Obtaining a qualified appraisal is an essential requirement for claiming an income tax deduction for charitable donations of property worth more than $5,000


PLR 201131006 (Apr. 13, 2011)
  • Proskauer Rose LLP
  • USA
  • November 15 2011

The IRS has ruled that an amendment of a qualified personal residence trust (“QPRT”) did not cause the trust to lose its special valuation status under I.R.C. 2702


IRS Notice 2011-82
  • Proskauer Rose LLP
  • USA
  • November 15 2011

The IRS has issued guidance on the portability election pursuant to this Notice