IRS relief for missed allocations of GST exemption.In Rev. Proc. 2004-46, the Service issued guidance allowing taxpayers to apply for relief for missed allocations of the generation-skipping transfer (GST GSTabbr. Greenwich sidereal time GST (in Australia, New Zealand, and Canada) Goods and Services Tax ) tax exemption tax exemption, immunity from the requirement of paying taxes. Federal, state, and usually local law provide exemption from taxation for a wide variety of organizations, usually not-for-profit, such as churches, colleges, universities, health care providers, various in a simplified format, under certain limited circumstances and if certain conditions are met. Generally, the relief applies to transfers that occurred before 2001 and were within the gift tax annual exclusion Annual exclusion A tax rule allowing the deduction of certain income from taxation. amount. The simplified format allows the taxpayer to file Form 709, United Stales Gift (and Generation-Skipping Transfer) Tax Return, for the year in question (whether or not that form was previously filed for that year) and attach a notice of allocation showing the relief requested. Many situations involving girls to irrevocable life insurance trusts may meet the procedure's restrictions. In contemplating the new procedure, tax advisors should be looking for Looking for In the context of general equities, this describing a buy interest in which a dealer is asked to offer stock, often involving a capital commitment. Antithesis of in touch with. trusts (e.g., life insurance trusts) that were overlooked for GST purposes, yet are intended to benefit multiple generations and receive annual exclusion gifts each year. The AICPA AICPA See American Institute of Certified Public Accountants (AICPA). Tax Division's Trust, Estate, and Gift Tax Technical Resource Panel's GST Regs Task Force asked the IRS An abbreviation for the Internal Revenue Service, a federal agency charged with the responsibility of administering and enforcing internal revenue laws. for this relief. See www.cpa2biz.com/ResourceCenters/Tax/Estate%2c+Gift%2c+Trust%2c+Fiduciary /GST_Safe_Harbor.htm. Prop. Regs. on Electing Out The IRS also issued proposed regulations (REG-153841-02, 7/13/04) on electing out of the deemed GST allocation under Sec. 2632(c)(1) for certain transfers to a GST trust. The proposed rules also provide guidance for making the election to treat a trust as a GST trust. If you have any comments or concerns about the proposed regulations, please contact Eileen Sherr at esherr@aicpa.org. Eileen Sherr, Technical Manager |
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