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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


2016 Estate, Gift and GST Tax Update: What This Means for Your Current Will, Revocable Trust and Estate Plan
  • Proskauer Rose LLP
  • USA
  • December 14 2015

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


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


Tax Court refused to admit appraisal into evidence when taxpayer failed to qualify the appraiser as an expert witness
  • Proskauer Rose LLP
  • USA
  • January 9 2014

In Tanenblatt v. Commissioner, the Tax Court made clear that it would not allow a taxpayer to circumvent the Federal Rules of Evidence or the Court's


New York Raises Basic Exclusion Amount to $5,250,000
  • Proskauer Rose LLP
  • USA
  • December 8 2016

On April 1, 2017, the amount of property that can pass free of New York State estate tax is set to rise to $5.25 million. Approximately three years


Using charitable giving techniques to offset income tax from Roth IRA conversions
  • Proskauer Rose LLP
  • USA
  • October 15 2010

In our June 2009 issue of Personal Planning Strategies, we explained that, beginning in 2010, all taxpayers, regardless of their income levels, will be eligible to take advantage of the opportunity to convert some or all of their traditional individual retirement accounts or other qualified retirement plans ("IRAs") to one or more Roth IRAs


Homestead exemption allowed for separated (but not divorced) taxpayer
  • Proskauer Rose LLP
  • USA
  • December 6 2010

In Wells v. Haldeos, Fla. Dist. Ct. App., 2nd Dist., Dkt. No. 2D09-4250 (10222010), an appeal by the property appraiser of Pasco County, Florida of a final judgment in favor of the taxpayer, the Florida District Court of Appeals for the 2nd Circuit held that a separated (but not divorced) taxpayer was eligible to receive a homestead exemption for his property in Florida despite the fact that his wife receives a residency-based property tax exemption on a separate property in New York


Late GST exemption allocation PLR 201313003
  • Proskauer Rose LLP
  • USA
  • May 1 2013

The IRS exercised its discretion to allow a taxpayer to make a late allocation of GST exemption. Over a six-year period, the taxpayer made transfers


Income tax is payable on proceeds from surrender of a life insurance policy used to repay a loan against the policy
  • Proskauer Rose LLP
  • USA
  • January 9 2014

In a recent income tax case, the Tax Court affirmed the principal that the proceeds received from surrender of an insurance policy in excess of the


Recharacterizing Roth IRA conversions
  • Proskauer Rose LLP
  • USA
  • December 15 2011

Beginning in 2010, many of our clients became eligible for the first time to convert their traditional individual retirement accounts or other qualified retirement plans ("Traditional IRAs") to Roth individual retirement accounts ("Roth IRAs") as a result of changes enacted under the Tax Increase Prevention and Reconciliation Act of 2005 ("TIPRA"