IRS Issues PLR Granting Extension for GST Exemption Allocation to Irrevocable Trust Transfers

The IRS has issued a private letter ruling on I.R.C. §2642 and Treas. Reg. §26.2642 granting a taxpayer a 120 day extension to allocate generation-skipping transfer (GST) exemption to transfers made to an irrevocable trust where the taxpayer’s original tax preparer failed to advise of the need to make the GST exemption allocation on the original gift tax return. The allocation will be effective as of the original transfer date using the federal gift tax value for determining the exemption amount. The taxpayer must file an amended Form 709 with the allocation within the extension period. The IRS determined the ...