We use cookies to customise content for your subscription and for analytics.
If you continue to browse Lexology, we will assume that you are happy to receive all our cookies. For further information please read our Cookie Policy.

Search results

Order by: most recent most popular relevance



Results: 1-10 of 93

Petition No. M090929A, NYS Dep’t of Taxation & Finance Advisory Opinion, TSB-A-10(1)(M)
  • Proskauer Rose LLP
  • USA
  • June 7 2010

In this Advisory Opinion, New York State determined that a non-resident decedent's interest in a revocable trust that owned interests in several limited liability companies ("LLCs") that held New York real property was not subject to New York State estate tax


June interest rates decrease slightly for GRATs, split interest charitable trusts, sales to defective grantor trusts and intra-family loans
  • Proskauer Rose LLP
  • USA
  • June 7 2010

The June applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3.2, slightly lower than the March rate


February interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts
  • Proskauer Rose LLP
  • USA
  • February 2 2012

The February 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4


IRS issues Notice 2011-101
  • Proskauer Rose LLP
  • USA
  • February 2 2012

In Notice 2011-101, the IRS announced that it is studying the tax implications of "decantings" when there is a change in the beneficial interests in a trust


Income tax deductions for charitable donations may be denied without a qualified appraisal Mohamed v. Commissioner, T.C. Memo 2012-152
  • Proskauer Rose LLP
  • USA
  • September 10 2012

Obtaining a qualified appraisal is an essential requirement for claiming an income tax deduction for charitable donations of property worth more than $5,000


Private letter ruling 201143002 (October 28, 2011)
  • Proskauer Rose LLP
  • USA
  • December 5 2011

The IRS ruled that a taxpayer's proposed exercise of his power of appointment will not cause assets of split trusts, combined trusts or sprinkle trusts to be includible in his gross estate under Section 2041, or to be subject to the GST tax


IRS announces it is reopening the offshore voluntary disclosure program
  • Proskauer Rose LLP
  • USA
  • February 2 2012

The IRS announced it is reopening the offshore voluntary disclosure program to help people hiding offshore accounts get current with their taxes


Tax Court upholds use of “defined value clause” on transfer of closely held stock to family trusts and charitable foundation Hendrix v. Commissioner, T.C. Memo 2011-133 (June 15, 2011)
  • Proskauer Rose LLP
  • USA
  • August 5 2011

In Hendrix v. Commissioner, the taxpayer scored yet another victory in a growing line of cases finding favorably for the use of defined value clauses


August interest rates for grats, sales to defective grantor trusts, intra-family loans and split interest charitable trusts continue decline
  • Proskauer Rose LLP
  • USA
  • August 5 2011

The August applicable federal rate (“AFR”) for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.2


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