PLR 200926021: Extension Granted to Treat Marital Trusts as Separate Trusts, Make Reverse QTip Election

In PLR 200926021, the Internal Revenue Service ruled that an estate would be granted an extension to make an election under reg. section 26.2652-2(c) to treat a marital trust as two separate trusts and to make a reverse qualified terminable interest property election under section 2652(a)(3) .