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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


Recharacterizing Roth IRA conversions
  • Proskauer Rose LLP
  • USA
  • December 15 2011

Beginning in 2010, many of our clients became eligible for the first time to convert their traditional individual retirement accounts or other qualified retirement plans ("Traditional IRAs") to Roth individual retirement accounts ("Roth IRAs") as a result of changes enacted under the Tax Increase Prevention and Reconciliation Act of 2005 ("TIPRA"


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


Private letter ruling 201203033 (january 20, 2012)
  • Proskauer Rose LLP
  • USA
  • March 6 2012

In PLR 201203033, the IRS ruled that a trust qualified as a designated beneficiary after a trust beneficiary released certain portions of a power of appointment


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


Use it or lose it - increased gift and GST exemption amounts expire on 123112
  • Proskauer Rose LLP
  • USA
  • September 1 2011

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


Creating a "GRAT": heads you win, tails you break even
  • Proskauer Rose LLP
  • USA
  • September 1 2011

Creating a grantor retained annuity trust (commonly referred to as a "GRAT") is a relatively simple way to transfer property to your children at virtually no gift tax cost


Decedent had no ownership interest in companies despite his involvement in the business
  • Proskauer Rose LLP
  • USA
  • July 1 2010

In Estate of Fortunato v. Commissioner, T.C. Memo 2010-105 (May 12, 2010), the Tax Court ruled that the decedent had no ownership interest in various companies despite his involvement in the operation of the companies


PLR 201131006 (Apr. 13, 2011)
  • Proskauer Rose LLP
  • USA
  • November 15 2011

The IRS has ruled that an amendment of a qualified personal residence trust (“QPRT”) did not cause the trust to lose its special valuation status under I.R.C. 2702