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Results: 1-10 of 93

6th Circuit finds regulation reasonable on generation-skipping transfer tax Estate of Timken, 2010 WL 1253627 (April 2, 2010)
  • Proskauer Rose LLP
  • USA
  • May 7 2010

The 6th Circuit found that Treasury Regulation 26.2601-1(b)(1)(v)(A), stipulating that the grandfathering exemption to the generation-skipping transfer tax (“GST”) does not apply when there is a post-statute exercise of lapse of a general power of appointment, is reasonable


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

The May applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 3


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


New estategiftgst tax exemption amounts for 2012
  • Proskauer Rose LLP
  • USA
  • December 5 2011

IRS Revenue Procedure 2011-52 announced the new estate, gift, and GST tax exemption amounts as adjusted for inflation for 2012


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


Freeman v. U.S. (E. D. Pennsylvania, January 30, 2012)
  • Proskauer Rose LLP
  • USA
  • March 6 2012

A U.S. District Court in Pennsylvania held that an estate was liable for penalties and interest for the late filing of an estate tax return because the executor did not have reasonable cause for filing after the deadline


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


Court rescinds nonqualified disclaimer and denies gift tax liability
  • Proskauer Rose LLP
  • USA
  • November 5 2010

In this case, a disclaimant's parents set up Qualified Personal Resident Trusts ("QPRTs") that passed to the disclaimant, Craig, and his sister after the QPRT terms expired


Court limits amount that surviving spouse was entitled to claim for tax on prior transfers under 2013
  • Proskauer Rose LLP
  • USA
  • November 5 2010

This case involves credits for tax on prior transfers under IRC 2013


November interest rates remain the same for GRATs but decline for sales to defective grantor trusts, and intra-family loans
  • Proskauer Rose LLP
  • USA
  • November 5 2010

The November applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2