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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


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


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


Valuation Discounts for Transfers of Interests in Family Entities May Be Severely Curtailed - You May Want To Act Now
  • Proskauer Rose LLP
  • USA
  • August 10 2016

On August 2, 2016, the Treasury Department and the Internal Revenue Service (the "IRS") issued proposed regulations under section 2704 (the "Proposed


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"


New York expands EPTL 10-6.6 to further liberalize trust "decanting"
  • Proskauer Rose LLP
  • USA
  • September 14 2011

On August, 17, 2011, New York Governor Andrew Cuomo signed into law Bill A8297 which expands the State's decanting statute (Estates, Powers and Trust Law 10-6.6


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


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


U.S. v. Blake, E.D.N.Y, No. 12-cv-02577
  • Proskauer Rose LLP
  • USA
  • June 3 2013

The U.S. District Court for the Eastern District of New York abstained from jurisdiction in a claim by the government to collect estate taxes because


Estate of Turner v. Comm’r, T.C. Memo 2011-209 (Aug. 30, 2011)
  • Proskauer Rose LLP
  • USA
  • November 15 2011

The Tax Court has held that (a) assets contributed to a family limited partnership (“FLP”) were includable in a decedent’s gross estate under section 2036(a) of the Internal Revenue Code of 1986, as amended (“I.R.C.”), and (b) premiums paid directly to a carrier on behalf of an insurance trust qualified for the annual gift tax exclusion as present interest gifts