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IRS PLR: Generation-Skipping Transfer Tax Exemption Allocation Opt-Out Extension Granted (IRC §2642)

Dec. 3, 2021, 5:00 AM

In two PLRs, a trust settlor received extra time under tax code Section 2642(g) to elect out of automatic allocation of generation-skipping transfer (GST) tax exemption for a transfer to the trust, which became “Family Trust” (PLR 202148002) or “Children’s Trust” (PLR 202148003) on the date on which the estate tax inclusion period with respect to the transfer closed for GST tax purposes. According to the representation, attorney failed to advise Settlor about the GST automatic allocation rules of Section 2632(c) and the ability to opt out (Section 2632(c)(5)), while Settlor filed a timely Form ...

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