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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"


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


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


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


Proposed Treas. Reg. 1.67-4
  • Proskauer Rose LLP
  • USA
  • November 15 2011

Treasury has issued new proposed Regulations in connection with what costs incurred by estates or non-grantor trusts are subject to the 2 floor for miscellaneous deductions under I.R.C. 67(a


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


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


Electing out of the application of the estate tax and allocating basis step-up for 2010 decedents
  • Proskauer Rose LLP
  • USA
  • August 9 2011

The legislation enacted in December 2010 retroactively reinstated the federal Estate tax for 2010 decedents but allows an applicable Executor to “opt out” of the Estate tax regime by making a “Section 1022 Election”