In PLR 200742015 (May 8, 2007), the IRS granted Executors an extension of time of 60 days from the PLR date to make the election under Treas. Reg. Sec.26.2652-2(c) to treat trust as two separate trusts, one of which has a zero inclusion ratio by reason of Decedent's GST exemption previously allocated to trust.
Posted by Lewis J. Saret, General Editor, Wealth Strategies Journal.
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