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Results: 1-10 of 154

The Tax Court holds, in a summary judgment ruling, that the Beneficiaries of gifts who are obligated to pay any potential estate tax liability arising from the gifts may decrease the value of the gift by the actuarial value of that obligation
  • Proskauer Rose LLP
  • USA
  • November 1 2013

In Steinberg v. Commissioner, 141 T.C. No. 8 (September 30, 2013), a mother (the "Parent") gave cash and securities to her daughters (the


November interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts
  • Proskauer Rose LLP
  • USA
  • November 15 2012

The November 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.0, which is a reduction from last month's rate of 1.2


Year-end planning strategies
  • Proskauer Rose LLP
  • USA
  • December 15 2011

We have experienced yet another year of financial instability, both here and across the shores, which continues to engender some degree of anxiety among our clients


Wealth management update
  • Proskauer Rose LLP
  • USA
  • May 7 2014

The May 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.4, up 0.2 from April. The May applicable


Estate of Koons v. Commissioner, T.C. Memo 2013-94
  • Proskauer Rose LLP
  • USA
  • June 3 2013

The Tax Court adopted the IRS's valuation of a revocable trust's interest in a business with mostly liquid assets, finding that the taxpayer's


Estate of Nancy P. Young v. United States (D. Mass., No. 1:11-cv-11829-RWZ, 121712)
  • Proskauer Rose LLP
  • USA
  • February 12 2013

In Estate of Nancy P. Young v. United States, the District Court upheld a latefiling penalty against an estate whose accountants advised it to file


Private Letter Ruling 201245004
  • Proskauer Rose LLP
  • USA
  • February 12 2013

The IRS ruled that the surviving spouse could disclaim her interest in an Individual Retirement Account ("IRA") even though she had received


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


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


Decedent's partnership interest in a partnership holding New York real property is not subject to New York estate tax
  • Proskauer Rose LLP
  • USA
  • December 5 2011

On October 12, 2011, the New York Department of Taxation and Finance issued an Advisory Opinion building upon its previous April 8, 2010 Advisory Opinion (TSB-A-11(1)M and TSB-A-10(1), respectively) regarding the conversion of real property interests into intangibles for New York estate tax purposes, in both cases ruling that a Florida decedent holding an interest in New York real property via an interest in a partnership (or an LLC) held by her revocable trust did not own an interest in the underlying real property for New York estate tax purposes