Monthly Archives: April 2012

Helpful Testamentary Charitable Lead Annuity Trust Private Letter Ruling

Posted on April 30, 2012 by lpaulhoodjr

KEY WORDS: Charitable Lead Trusts EXECUTIVE SUMMARY: In this private letter ruling, the IRS held that a zeroed out testamentary charitable lead annuity trust (“T-CLAT”) that used an ascending (i.e., back-loaded) charitable payout was a qualified charitable lead annuity trust. … Continue reading →

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Proposed Ante-Nuptial Agreement Fails to Qualify for the Marital Deduction

Posted on April 30, 2012 by lpaulhoodjr

KEY WORDS: Marital Deduction; Tenancy by the Entirety; Marriage Contracts EXECUTIVE SUMMARY: In this private letter ruling, the IRS held that an arrangement whereby two spouses proposed to limit what the survivor between them could do with the deceased spouse’s … Continue reading →

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Tax Court Deals the IRS Another Blow in a Defined Value Gift Case

Posted on April 1, 2012 by lpaulhoodjr

Executive Summary: In this federal gift tax case, the Tax Court determined in a memorandum opinion that the taxpayers’ respective defined value gift clauses were enforceable under state law, were defined value gifts of LLC membership interests instead of gifts … Continue reading →

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