ESTATE TAX

REG–147775–06, page 916. Proposed regulations under section 2642 of the Code identify the standards that the IRS will apply in determining whether to grant a transferor or a transferor’s estate an extension of time under section 2642(g)(1) to: (1) allocate generation-skipping transfer (GST) exemption, as defined in section 2631, to a transfer; (2) elect under section 2632(b)(3) (the election not to have the deemed allocation of GST exemption apply to a direct skip); (3) elect under section 2632(c)(5)(A)(i) (the election not to have the deemed allocation of GST exemption apply to an indirect skip or transfers made to a particular trust); and (4) elect under section 2632(c)(5)(A)(ii) (the election to treat any trust as a GST trust for purposes of section 2632(c)). The regulations also identify situations with facts that do not satisfy the standards for granting relief and in which, as a result, the relief described above will not be granted. A public hearing is scheduled for August 5, 2008.

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