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Results: 11-20 of 166

Surviving spouse is not treated as the payee of the decedent’s IRA and therefore could not take the IRA and roll it over into an IRA in her own name
  • Proskauer Rose LLP
  • USA
  • March 10 2010

In this PLR, the IRS found that the decedent's surviving spouse was not treated as the payee of the decedent's IRA, and therefore she could not take the IRA and roll it over into an IRA in her own name


Proposed Treas. Reg. 1.67-4
  • Proskauer Rose LLP
  • USA
  • November 15 2011

Treasury has issued new proposed Regulations in connection with what costs incurred by estates or non-grantor trusts are subject to the 2 floor for miscellaneous deductions under I.R.C. 67(a


IRS Form 8939 and instructions released
  • Proskauer Rose LLP
  • USA
  • November 15 2011

The IRS has released Form 8939, Allocation of Increase in Basis for Property Acquired From a Decedent


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


Federal district court finds transfer of interests in LLC to children does not qualify for the annual gift tax exclusion Fisher v. Commissioner, No. 1:08-CV-00908 (March 11, 2010)
  • Proskauer Rose LLP
  • USA
  • May 7 2010

A U.S. District Court in Indiana found the transfer of interests in a LLC to children did not qualify for the annual gift tax exclusion because the interests were considered “future” rather than “present” interests in property due to operating agreement restrictions on the children’s rights relating to the property


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


Sale of assets for fair market value between a marital trust and a nonmarital trust to settle a dispute between beneficiaries and trustees of the trusts was neither a taxable gift nor a transfer of an income interest in a QTIP Priv. Ltr. Rul. 201119003
  • Proskauer Rose LLP
  • USA
  • July 5 2011

In this private letter ruling, the issue was whether the transfer of assets for fair market value between a marital trust and a nonmarital trust resulted in a taxable gift or a disposition of an income interest in qualified terminable interest property (“QTIP”


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

The October Section 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.6, up 0.2 from September. The


Proposed Regulations Seek to Curtail Valuation Discounts
  • Proskauer Rose LLP
  • USA
  • December 8 2016

The most successful estate planning techniques pass significant value from one generation to the next by freezing or establishing an appreciating


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