IRC Section 2642(g)(1) Proposed Regulations

On April 17, 2008, proposed regulations were issued providing guidance on the application of Internal Revenue Code Section 2642(g)(1). The proposed regs describe the circumstances under which an extension of time will be granted to: allocate generation-skipping transfer (GST) tax exemption to a transfer; elect under IRC Section 2632(b); not have the deemed allocation of GST exemption apply to a direct