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

The IRS has published a private letter ruling on §2056(b)(7) and Treas. Regs. §301.9100 granting an extension of time for the taxpayer’s estate to make a qualified terminable interest property (QTIP) election and a reverse QTIP election under IRC §2652(a)(3) with respect to a specific trust. The ruling grants the taxpayer’s estate an extension of 120 days from the date of the letter to file a supplemental Form 706 to make these elections for the applicable taxable year. [PLR 202532003]

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