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Results: 1-10 of 132

Estate of Stone v. Comm'r, T.C. Memo 2012-48 (2222012)
  • Proskauer Rose LLP
  • USA
  • April 2 2012

In Stone, a recent Tax Court case, the Court determined that the transfer of undeveloped woodlands to a family limited partnership (an "FLP") was a bona fide sale, since the record established that the FLP was created for legitimate non-tax reasons


March interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts
  • Proskauer Rose LLP
  • USA
  • March 6 2012

The March 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4


Private letter ruling 201203033 (january 20, 2012)
  • Proskauer Rose LLP
  • USA
  • March 6 2012

In PLR 201203033, the IRS ruled that a trust qualified as a designated beneficiary after a trust beneficiary released certain portions of a power of appointment


Private letter ruling 201151003 (December 23, 2011)
  • Proskauer Rose LLP
  • USA
  • March 6 2012

The IRS granted a decedent's estate an extension to make the alternate valuation election where the executor of the estate relied on advice of the CPA that he hired to prepare and file the decedent's estate tax return


Pruco Life Ins. Co. v. Brasner (S. D. Florida, November 14, 2011)
  • Proskauer Rose LLP
  • USA
  • January 9 2012

A U.S. District Court in Florida held that an investor who acquired a life insurance policy under a stranger owned life insurance ("STOLI") arrangement lacked an insurable interest, and that the insurer did not have to pay the $10 million death benefit


Estate of Liftin (November 8, 2011)
  • Proskauer Rose LLP
  • USA
  • January 9 2012

The US Court of Federal Claims held that an estate adequately alleged facts that its failure to timely file a federal estate tax return was due to reasonable cause and not willful neglect, where the estate relied in good faith on expert advice of an estate planning attorney


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


Freeman v. U.S. (E. D. Pennsylvania, January 30, 2012)
  • Proskauer Rose LLP
  • USA
  • March 6 2012

A U.S. District Court in Pennsylvania held that an estate was liable for penalties and interest for the late filing of an estate tax return because the executor did not have reasonable cause for filing after the deadline