IRS Issues Private Letter Ruling Granting Extension for GST Trust Election to Allow Automatic Exemption Allocation

The IRS issued a private letter ruling on I.R.C. §§2642 and 2632, granting a 120-day extension for a taxpayer to elect to treat a trust as a generation-skipping transfer (GST) trust, allowing automatic allocation of GST exemption to prior transfers after finding the taxpayer acted reasonably and in good faith when relying on a tax professional who failed to make the election. [PLR 202610004]

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