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Results: 1-10 of 93

Now is the time to take advantage of changes to the federal gift and generation-skipping transfer taxes in 2010
  • Proskauer Rose LLP
  • USA
  • October 15 2010

Two changes to the Federal wealth transfer system that were enacted pursuant to the Economic Growth and Tax Relief Reconciliation Act of 2001 (the "2001 Act") during President Bush's first year in office create, at least in the absence of retroactive legislation, a favorable environment in 2010 for gift planning


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 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


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


New York expands EPTL 10-6.6 to further liberalize trust "decanting"
  • Proskauer Rose LLP
  • USA
  • September 14 2011

On August, 17, 2011, New York Governor Andrew Cuomo signed into law Bill A8297 which expands the State's decanting statute (Estates, Powers and Trust Law 10-6.6


Former trustee of private foundation found not to be a "disqualified person" for the purpose of subsequent sale to foundation - Private Letter Ruling 201130008 (July 29, 2011)
  • Proskauer Rose LLP
  • USA
  • September 14 2011

In PLR 200130008, a former trustee of a private foundation, who was also the spouse of another former trustee of the private foundation, was determined not to be a disqualified person under IRC 4941(a) upon her and spouse's resignations as trustees


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"


Estate loan interest held deductible
  • Proskauer Rose LLP
  • USA
  • December 5 2011

In Estate of Vincent J. Duncan Sr. v. Commissioner, T.C. Memo 2011-255, No. 7549-10 (October 31, 2011), the Tax Court upheld a Section 2053 deduction for interest on a loan taken to pay estate tax


Final form 706 is released for 2011 decedents
  • Proskauer Rose LLP
  • USA
  • December 5 2011

The IRS has released the final Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return for 2011 decedents, which incorporates the changes in estate and GST tax rates and exemptions due to the Tax Relief, Unemployment Insurance Reauthorization and Job Creation Act of 2010, as well as indexing and other changes


Revenue procedure 2011-48 (October 14, 2011)
  • Proskauer Rose LLP
  • USA
  • December 5 2011

The IRS has issued guidance on the procedure for the filing and resolution of a Protective Claim for Refund of estate tax that is based on a deduction for a claim or expense under section 2053 of the Internal Revenue Code (Code