Recent IRS Private Letter Rulings

There have been three recent PLRs issued by the IRS.  These include:

• PLR 201144001 - The IRS ruled that sections 2702(a)(1) and 2702(a)(2) won't apply to the modification and amendment and restatement of a trust and that on execution of the amendment and restatement, the settlor's children will make transfers of property by gift under section 2501 to the settlor.
• PLR 201144026 - The IRS granted extensions to allocate their available generation-skipping transfer tax exemptions to transfers to two trusts.
• PLR 201144011 - The IRS granted the executrix of an estate an extension to make an alternate valuation election under section 2032.

See IRS Written Determinations.

Posted by William Alan Nelson II, Associate Editor, Wealth Strategies Journal