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Results: 1-10 of 106

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


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"


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 - 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


Trust cannot claim charitable deduction for fair market value of appreciated property donated to charity, despite fact that property was purchased with trust gross income
  • Proskauer Rose LLP
  • USA
  • December 6 2010

In Chief Counsel Advice 201042023 (10222010), IRS has held that a trust cannot claim an income tax charitable deduction for the fair market value of appreciated property donated to charity, despite the fact that the property was purchased with the trust's gross income from prior years and was traceable to that income


Tax Court applies 25 percent lack of marketability discount to valuation of interest in limited partnership holding timber property, but finds that lack of control discount is already implicit in valuation methodology applied to property Estate of Giust
  • Proskauer Rose LLP
  • USA
  • August 5 2011

At issue in Giustina was the valuation of a minority interest in a limited partnership that owned approximately 48,000 acres of timber property


U.S. government sues estate and donees of J. Howard Marshall II for unpaid gift taxes
  • Proskauer Rose LLP
  • USA
  • November 5 2010

The U.S. government is suing the estate and donees of J. Howard Marshall for a combined $85 million of unpaid gift and GST taxes


Estate of Giovacchini v. Commissioner, T.C. Memo 2013-27
  • Proskauer Rose LLP
  • USA
  • March 8 2013

The Tax Court redetermined values for estate and gift tax purposes of a large parcel of more than 2,500 acres of land near Lake Tahoe, California