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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


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"


Use it or lose it - increased gift and GST exemption amounts expire on 123112
  • Proskauer Rose LLP
  • USA
  • September 10 2012

On December 17, 2010, the Tax Relief, Unemployment Insurance Reauthorization, and Job Creation Act of 2010 (the "2010 Act") was signed into law, making significant modifications to the estate, gift and generation-skipping transfer ("GST") taxes


Chief Counsel Advice Memorandum 201208026 (9282011)
  • Proskauer Rose LLP
  • USA
  • April 2 2012

In a recently released Memorandum, the IRS Office of Chief Counsel concludes that contributions made by Settlors to a discretionary trust for their descendants were taxable gifts, since (1) the Settlors had not retained any rights that would make the gifts incomplete and (2) the withdrawal powers granted to the beneficiaries were unenforceable in state court and thus illusory


Using charitable giving techniques to offset income tax from Roth IRA conversions
  • Proskauer Rose LLP
  • USA
  • October 15 2010

In our June 2009 issue of Personal Planning Strategies, we explained that, beginning in 2010, all taxpayers, regardless of their income levels, will be eligible to take advantage of the opportunity to convert some or all of their traditional individual retirement accounts or other qualified retirement plans ("IRAs") to one or more Roth IRAs


Intra-family loans: a simple yet effective estate planning tool
  • Proskauer Rose LLP
  • USA
  • September 1 2011

An intra-family loan is a basic estate-planning technique which has a very low transaction cost


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


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


New York State changes personal income tax rates
  • Proskauer Rose LLP
  • USA
  • February 2 2012

New York has modified the personal income tax rate schedule for tax years 2012 through 2014


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