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Article

Proskauer Rose LLP | USA | 5 Jul 2011

Estate not entitled to discount the value of three marital trusts for claims by ESOP members against the marital trusts’ assets Estate of Foster v. Comm’r, T.C. Memo 2011-95 (4282011)

In Foster, the Tax Court considered the following: (1) whether an estate was entitled to discount the value of assets in three marital trusts due to the potential for litigation; and (2) whether assets in the marital trusts could be discounted for lack of control over and lack of marketability of the marital trusts’ assets.

Article

RPC | United Kingdom | 17 May 2011

Unravelling transactions the party’s over

In March the Court of Appeal handed down its eagerly awaited decision in Pitt v Holt, unexpectedly overturning what has been known as the principle set out in Re Hastings-Bass.

Article

RPC | United Kingdom | 21 Mar 2011

Unravelling transactions: close your eyes?

The Court of Appeal has now handed down its eagerly awaited decision in Pitt and Another v Holt and Another, unexpectedly overturning what has been known as the principle set out in Re Hastings-Bass.

Article

RPC | United Kingdom | 11 Mar 2011

Unravelling transactions: the party’s over

Earlier this week the Court of Appeal handed down its eagerly awaited decision in Pitt and Another v Holt and Another, unexpectedly overturning what has been known as the principle set out in Re Hastings-Bass.

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