Government, May I Fix My GST Mistake? Regulations Offer Guidance on Generation-Skipping Tax Exemption Allocation Relief

Private client partner Lisa Presser and associate Brian Balduzzi authored an article for The Legal Intelligencer titled, “Government, May I Fix My GST Mistake? Regulations Offer Guidance on Generation-Skipping Tax Exemption Allocation Relief.”

In the article, the authors discuss the new regulations, effective for relief filed on or after May 6, 2024, clients can request a private letter ruling (PLR) to correct past mistakes in GST exemption allocations and elections. The final regulations offer a more streamlined and thorough process for clients and their advisers to plan strategically for requesting relief from the IRS for these mistakes.

The authors touch on the generation-skipping transfer tax (GST), private letter ruling request, factors for the donor’s reasonableness and good faith, factors for granting relief that would not prejudice the government’s interests and the role of affidavit and supporting evidence.

The full article is available to The Legal Intelligencer subscribers.