In two separate advisory emails the IRS has provided advice on Section 6166(g) Estate Tax Deferral. The first email advised that a change in the form of business that holds property would not qualify as a divestment of the interest in the property from the gross estate under Section 6166. The second email advised that distribution of 51% of Section 6166 property to other family members by gift would not be an accelerating event when the transfers resulted because of the transferor's death. The full summary and emails can be read at Tax Analysts.
See "Change in Form of Business Wouldn't Be a Divestment for Purposes of Estate Tax Deferral Provision," 2011 TNT 205-63 (Oct. 11, 2011).
See "Distribution of Property By Gift Is Not Accelerating Event," 2011 TNT 205-64 (Oct. 11, 2011).
Posted by Andrew Hodes, Associate Editor, Wealth Strategies Journal.
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