A Guide to Allocation of Generation Skipping Tax (GST ...
Simplified Method for Relief: Rev. Proc. 2004-46 provides an alternative to the PLR process to obtain an extension of time to timely allocate the GST tax exemption for taxpayers meets the following requirements: ... (22) The IRS has discretion to allow retroactive allocations. IRC [section] 2642(g)(1)(B). See Treas. Reg. [section] 301.9100-3 ... ................
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