Monthly Archives: September 2007

Surviving and Thriving In the Tax Patent Era

By Gerald B. Treacy, Jr.

Originally Published in Trusts & Estates, September 2007

A patent applicant offers a guide to practitioners on how to avoid infringement, malpractice–and depriving clients of good strategies Just as things seemed to be quieting down after the Pension Protection Act of 2006, along came the latest challenge to the peace of the estate-planning world: tax patents. In early 2006, an infringement suit was […]

Rulings Go Beyond ‘Plain Vanilla’ Foundations

By Gerald B. Treacy, Jr.

Originally Published in Taxation of Exempts, September 2007

Thus far, 2007 has generated four private letter rulings of more than casual interest relating to private foundations. Unusually, two of the rulings relate to the generally quiet area of private operating foundations under Section 4942(j)(3). A private operating foundation, or POF, is an “elevated” form of private foundation, which, in contrast to its more […]