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Estate of Turner v. Comm’r, T.C. Memo 2011-209 (Aug. 30, 2011)
  • Proskauer Rose LLP
  • USA
  • November 15 2011

The Tax Court has held that (a) assets contributed to a family limited partnership (“FLP”) were includable in a decedent’s gross estate under section 2036(a) of the Internal Revenue Code of 1986, as amended (“I.R.C.”), and (b) premiums paid directly to a carrier on behalf of an insurance trust qualified for the annual gift tax exclusion as present interest gifts.


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.


Tax Court finds taxpayers who employed Roth IRA conversion tax shelter were liable for excise tax and penalties Paschall v. Commissioner, 137 T.C. No. 2 (July 5, 2011); Swanson v. Commissioner, T.C. Memo 2011-156 (July 5, 2011)
  • Proskauer Rose LLP
  • USA
  • August 5 2011

In the companion cases of Paschall v. Commissioner and Swanson v. Commissioner, the Tax Court found that taxpayers who employed a Roth IRA conversion tax shelter were liable for excise taxes on account of excess contributions to the Roth IRAs and were also liable for failure to file penalties.


Insurance policy in pension plan will be treated as ordinary life insurance contract and death benefits considered incidental if less than 50 of the participant’s total contributions to the plan are applied to pay premiums on the life insurance contract
  • Proskauer Rose LLP
  • USA
  • December 6 2010

In Private Letter Ruling 201043048 (10292010), IRS ruled that an insurance policy in a pension plan will be treated as an ordinary life insurance contract and the death benefits will be considered incidental, as less than 50 of the participants' total contributions to the plan were applied to pay premiums on the life insurance contract.


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.


Haiti earthquake relief donations made before March 1, 2010 may be deducted on 2009 returns
  • Proskauer Rose LLP
  • USA
  • March 10 2010

On January 22, 2010, President Obama signed into law a provision which allows taxpayers to claim a charitable deduction in tax year 2009 for donations made after January 11, 2010 and before March 1, 2010 for the relief of victims of the Haiti earthquake.



Elaine Bucher
  • Proskauer Rose LLP