IRS relief for missed allocations of GST exemption.
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 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 Tax Division's Trust, Estate, and Gift Tax Technical Resource
Panel's GST Regs Task Force asked the IRS 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 firstname.lastname@example.org.
Eileen Sherr, Technical Manager
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|Title Annotation:||generation skilling transfer tax|
|Publication:||The Tax Adviser|
|Date:||Oct 1, 2004|
|Previous Article:||Final version of Schedule M-3 available.|
|Next Article:||Electing to defer advance payments under Rev. Proc. 2004-34.|