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Proskauer Rose LLP Document Search Results (389) Show: results per page Sort by:  | Favorable "DING Trust" Rulings - PLRs 201310002 - 201310006
Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 2013 In five related rulings, the IRS issued favorable holdings addressing the income and gift tax consequences of so-called "DING trusts." The acronym stands for "Delaware Incomplete Non-Grantor" trusts, but the trust does not need to be established in Delaware. In fact, the trusts...
| | Villareale v. Commissioner, T.C. Memo 2013-74
Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 2013 The Tax Court determined the taxpayer was not entitled to a charitable contribution deduction for contributions she made to a public charity she created, where she failed to have the charity issue written acknowledgements of the contributions.
| | Contractors: Is Your Company’s Web Site Accessible to Individuals With Disabilities? (OFCCP Thinks It Should Be)
Matt Allen Decker Nusbaum; Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 3, 2013 In December, 2011, the Office of Contract Compliance Programs (OFCCP) caused much consternation among the federal contracting community by publishing proposed changes to the affirmative action and nondiscrimination obligations of contractors and subcontractors regarding individuals with...
| | Like-kind Exchange of Life Insurance Policies - PLR 201304003
Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 2013 The IRS privately ruled that the exchange by an irrevocable trust of a second-to-die life insurance policy for a new first-to-die policy would qualify as a like-kind exchange under Internal Revenue Code Section 1035 with no recognition of gain or loss.
| | Villareale v. Commissioner, T.C. Memo 2013-74
Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 2013 The Tax Court determined the taxpayer was not entitled to a charitable contribution deduction for contributions she made to a public charity she created, where she failed to have the charity issue written acknowledgements of the contributions.
| | PBGC Releases 4062(e) Enforcement Guidelines
Justin Stanley Alex; Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 2, 2013 ERISA section 4062(e) addresses situations in which an employer ceases operations at a facility in any location and, as a result, separates more than 20% of its employees who participate in the employer’s defined benefit plan. If a 4062(e) event occurs, the employer is subject to a liability...
| | Late GST Exemption Allocation - PLR 201313003
Proskauer Rose LLP;
Legal Alert/Article May 6, 2013, previously published on May 2013 The IRS exercised its discretion to allow a taxpayer to make a late allocation of GST exemption. Over a six-year period, the taxpayer made transfers to two irrevocable trusts he created for the benefit of his issue. The transfers occurred sometime prior to the enactment of the automatic allocation...
| | Like-kind Exchange of Life Insurance Policies - PLR 201304003
Proskauer Rose LLP;
Legal Alert/Article May 3, 2013, previously published on May 2013 The IRS privately ruled that the exchange by an irrevocable trust of a second-to-die life insurance policy for a new first-to-die policy would qualify as a like-kind exchange under Internal Revenue Code Section 1035 with no recognition of gain or loss.
| | Late GST Exemption Allocation ¿ PLR 201313003
Proskauer Rose LLP;
Legal Alert/Article May 3, 2013, previously published on May 2013 The IRS exercised its discretion to allow a taxpayer to make a late allocation of GST exemption. Over a six-year period, the taxpayer made transfers to two irrevocable trusts he created for the benefit of his issue. The transfers occurred sometime prior to the enactment of the automatic allocation...
| | Favorable "DING Trust" Rulings - PLRs 201310002 - 201310006
Proskauer Rose LLP;
Legal Alert/Article May 3, 2013, previously published on May 2013 In five related rulings, the IRS issued favorable holdings addressing the income and gift tax consequences of so-called "DING trusts." The acronym stands for "Delaware Incomplete Non-Grantor" trusts, but the trust does not need to be established in Delaware. In fact, the trusts...
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