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Results: 11-20 of 158

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


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


Tax Court finds that life insurance proceeds were estate tax includible on account of decedent’s retained incidents of ownership, that annuities were estate tax includible, and that estate was liable for failure to file timely penalty Estate of Coaxum v
  • Proskauer Rose LLP
  • USA
  • August 5 2011

In Coaxum v. Commissioner, the Tax Court found that the decedent retained incidents of ownership in six life insurance policies, rendering their values includible in the gross estate, that the value of the annuities owned by the decedent was includible in the gross estate, and that the estate was liable for a failure to file timely penalty


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


Malpractice claim against an estate was too uncertain to be deductible as of date of death and thus, the deduction would be based only on the amount actually paid by the estate Estate of Gertrude H. Saunders, et al. v. Comm’r, 136 T.C. No. 18 (4282011
  • Proskauer Rose LLP
  • USA
  • July 5 2011

In Saunders, a malpractice claim for $90,000,000 was filed against the decedent’s predeceased husband’s estate, alleging a breach of fiduciary duty by the decedent’s husband


Wealth Management Update - June 2016
  • Proskauer Rose LLP
  • USA
  • June 2 2016

The June 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.8, which has remained constant since March


Wealth Management Update - February 2016
  • Proskauer Rose LLP
  • USA
  • February 8 2016

The February 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.2, which is the same as January’s rate


Wealth Management Update - July 2016
  • Proskauer Rose LLP
  • USA
  • July 1 2016

The July 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.8, which has remained constant since March


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


2014 estate, gift and GST tax update: what this means for your current will, revocable trust and estate plan
  • Proskauer Rose LLP
  • USA
  • December 19 2013

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