IRS PLR: Extension of Time to Make QTIP and Reverse QTIP Trust Elections Granted (IRC §2056)

Executor of decedent’s estate received an extension of time to make a QTIP election under I.R.C. §2056(b)(7) with respect to the QTIP trust and a “reverse” QTIP election under §2652(a)(3) with respect to the Generation Skipping Transfer (GST) exempt portion of the QTIP trust. Decedent died survived by spouse and established a revocable trust that was divided into a QTIP trust and bypass trust. The trust provided that the trustee shall divide the QTIP trust into two trusts, a GST exempt trust and a GST nonexempt trust. The GST exempt trust was to hold a portion of the ...