IRS Issues PLR Granting Extension for GST Exemption Allocation

The IRS has issued a private letter ruling on I.R.C. §2642 and Treas. Reg. §26.2642 granting taxpayer a 120-day extension to allocate generation-skipping transfer (GST) exemption to transfers made to trusts where the original Form 709 was prepared but never filed due to accountant error, finding taxpayer acted reasonably and in good faith by relying on qualified tax professional advice and demonstrating contemporaneous intent to make the allocation. [PLR 202618003]

This story was produced by Bloomberg Tax Automation, and edited by Bloomberg Tax staff.