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Tuesday, March 07, 2017

IRS Limiting GST Private Letter Rulings and Presubmission Conferences

At a recent Federal Bar Association Tax Law Conference, an IRS Chief Counsel branch chief advised that due to budget cuts:

a. The IRS has temporarily suspended issuing private letter rulings regarding modifications to generation-skipping transfer exempt trusts, and

b. The IRS has temporarily suspended pre-submission conferences in regard to estate, gift and generation-skipping transfer tax issues before the submission of a private letter ruling. This procedure allowed taxpayers to have a preliminary, nonbinding discussion with IRS personnel before submitting a private letter ruling request.

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