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Results: 1-10 of 93

Estate of Stone v. Comm'r, T.C. Memo 2012-48 (2222012)
  • Proskauer Rose LLP
  • USA
  • April 2 2012

In Stone, a recent Tax Court case, the Court determined that the transfer of undeveloped woodlands to a family limited partnership (an "FLP") was a bona fide sale, since the record established that the FLP was created for legitimate non-tax reasons


Estate of Liftin (November 8, 2011)
  • Proskauer Rose LLP
  • USA
  • January 9 2012

The US Court of Federal Claims held that an estate adequately alleged facts that its failure to timely file a federal estate tax return was due to reasonable cause and not willful neglect, where the estate relied in good faith on expert advice of an estate planning attorney


IRS Notice 2012-21 (352012)
  • Proskauer Rose LLP
  • USA
  • April 2 2012

In order for a surviving spouse to retain use of a deceased spouse's unused estate tax exemption, he or she must make a portability election on a timely filed federal estate tax return for the deceased spouse, even if no federal return needs to be filed because the decedent's assets were below his or her remaining federal estate tax exemption amount


Chief Counsel Advice Memorandum 201208026 (9282011)
  • Proskauer Rose LLP
  • USA
  • April 2 2012

In a recently released Memorandum, the IRS Office of Chief Counsel concludes that contributions made by Settlors to a discretionary trust for their descendants were taxable gifts, since (1) the Settlors had not retained any rights that would make the gifts incomplete and (2) the withdrawal powers granted to the beneficiaries were unenforceable in state court and thus illusory


General explanations of the administration's fiscal year 2013 revenue proposals (February 2012)
  • Proskauer Rose LLP
  • USA
  • April 2 2012

Each year, the U.S. Department of the Treasury issues a report setting forth the revenue proposals of the current presidential administration


April interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts
  • Proskauer Rose LLP
  • USA
  • April 2 2012

The April 7520 rate for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4


January interest rates for GRATs, sales to defective grantor trusts, intra-family loans and split interest charitable trusts
  • Proskauer Rose LLP
  • USA
  • January 9 2012

The January applicable federal rate ("AFR") for use with estate planning techniques such as CRTs, CLTs, QPRTs and GRATs is 1.4


IRS issues Revenue Ruling 2011-28
  • Proskauer Rose LLP
  • USA
  • January 9 2012

On December 5, 2011, the IRS issued Revenue Ruling 2011-28, holding that a grantor's retention of the power, exercisable in a non-fiduciary capacity, to acquire a life insurance policy held in a trust by substituting other assets of equal value will not cause inclusion of the policy in the grantor's gross estate under IRC Section 2042, as long as certain guidelines are met


IRS issues proposed Treasury Regulations 20.2032-1
  • Proskauer Rose LLP
  • USA
  • January 9 2012

The IRS withdrew and reissued proposed Treasury Regulations Section 20.2032-1 on November 18, 2011


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