PLR 201329005
Jan 01, 2013OUTCOME: Granted By IRS.
IRC Sec. 355 spin-off of a corporate subsidiary in a 368(a)(1)(D).
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OUTCOME: Granted By IRS.
IRC Sec. 355 spin-off of a corporate subsidiary in a 368(a)(1)(D).
OUTCOME: Taxpayer victory
The composition of the decedent's estate for federal estate tax purposes and the valuation thereof
OUTCOME: Granted by IRS
The reformation of a testamentary trust, under IRC 2055(e), into a CLAT and a CRUT, will qualify for the estate tax charitable deduction.
OUTCOME: Granted by IRS
A 501(c)(3)'s participation in a joint venture with banks will not jeorpardize its tax status or generate unrelated business income.