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Substantial Compliance GST Exemption
Husband and Wife created an irrevocable trust for each of their children and any descendants of those children. Over a five-year period, Husband and Wife transferred assets to each trust, filed tax returns listing the gifts as direct skips, and allocated portions of their GST exemptions to each trust to cover the transfers. Although the couple had ignored tax return instructions by not attaching notices of allocation of the GST exemption, the IRS found that by providing adequate information on the gift tax return, there was substantial compliance with the requirements and the intent to allocate the GST exemption to the trusts was evident. Thus, the IRS deemed the allocations of GST to be timely.
Source: Let. Rul. 200040013
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Sponsored by James J. Eccleston, an attorney representing stockbrokers, financial planners and
investors nationwide in arbitration, litigation and regulatory matters, and a shareholder with the law firm
Shaheen, Novoselsky, Staat, Filipowski & Eccleston
P.C.(www.snsfe-law.com). This Web site contains material
of general interest. It is neither intended to, nor constitutes, either legal advice or investment advice.
Always consult an attorney and/or investment advisor when building and protecting your wealth.
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