In PLR 201006008,
the
IRS allowed a married couple an extension to allocate available generation skipping tax exemptions to a transfer to two trusts due to the facts that (1) the couple's attorney failed to advise the couple for the year at issue to file gift tax returns and to allocate their generation-skipping tax exemption and (2) the couple intended to elect to split gifts in regards to the transfer to the two trusts.
See also Extension Granted to Allocate GSTT Exemptions, 2010 TNT 34-54 (February 22, 2010).

Leave a comment