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Results: 11-20 of 164

Tax court finds transfer of an interest in a limited partnership and timberland to an FLP was not includible in the decedent’s gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration
  • Proskauer Rose LLP
  • USA
  • March 10 2010

This Tax Court decision provides another Section 2036 victory for the taxpayer by holding that assets transferred to an FLP were not includible in the decedent's gross estate under Section 2036(a) because the transfer was a bona fide sale for adequate and full consideration


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 holds that trusteebeneficiary's power to invade trust principal for her "welfare" is limited by an ascertainable standard and trust principal not includible in her estate under IRC 2041(b)(1)(a) estate of Ann R. Chancellor, et al. v. Commiss
  • Proskauer Rose LLP
  • USA
  • September 14 2011

Frequently, trust agreements ensure that the principal invasion power held by a trustee who is also a beneficiary is limited to distributions for the beneficiary's "health, education, maintenance and support"


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


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

The September 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4, which is the same as the August rate


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


New Jersey Estate Tax Exemption Raised to $2,000,000; Estate Tax to be Phased Out
  • Proskauer Rose LLP
  • USA
  • December 8 2016

On January 1, 2017, the amount of property that can pass free of New Jersey State estate tax is set to rise to $2 million. On January 1, 2018, the


Wealth management update
  • Proskauer Rose LLP
  • USA
  • May 8 2015

The May 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.8, which is a slight decrease from April's rate


Wealth management update
  • Proskauer Rose LLP
  • USA
  • April 22 2015

The Obama Administration has recently announced its Fiscal Year 2016 Revenue Proposals in its annual "Greenbook." The Greenbook sets forth the


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