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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


Keller v. United States, 5th Cir., No. 10-41311 (092512)
  • Proskauer Rose LLP
  • USA
  • November 15 2012

In Keller, the Fifth Circuit Court of Appeals ruled that an estate was entitled to an estate tax refund for the discounted value of a family limited partnership ("FLP") that was created during the decedent's lifetime but not fully funded until after the decedent's death


2014 estate, gift and GST tax update: what this means for your current will, revocable trust and estate plan
  • Proskauer Rose LLP
  • USA
  • December 19 2013

As we previously reported, the American Taxpayer Relief Act of 2012 (the "Act") made the following permanent: (1) the reunification of the estate and


One year later
  • Proskauer Rose LLP
  • USA
  • December 19 2013

This time last year, we found ourselves in a whirlwind of advising clients to maximize transfer tax planning opportunities. We worked to ensure that


Villareale v. Commissioner, T.C. Memo 2013-74
  • Proskauer Rose LLP
  • USA
  • May 1 2013

The Tax Court determined the taxpayer was not entitled to a charitable contribution deduction for contributions she made to a public charity she


Federal exclusion from gift, estate and generation-skipping transfer taxes increases to $5,340,000 in 2014
  • Proskauer Rose LLP
  • USA
  • November 1 2013

In Revenue Ruling 2013-35, the IRS announced certain inflation adjustments to tax exemptions and deductions. The IRS increased the basic exclusion


November interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts
  • Proskauer Rose LLP
  • USA
  • November 1 2013

The November 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.0. This is down from October's 2.4


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


Wealth management update
  • Proskauer Rose LLP
  • USA
  • September 4 2014

The September 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 2.2, the same rate as August. The September


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