IRS Issues Estate 税 Guidance Requested by 188bet亚洲真人体育下载

The Internal 牧师enue Service (IRS), acting on a request by the American Institute of CPAs (188bet亚洲真人体育下载), has issued much needed guidance for executors of estates, clarifying the effect of making both a qualified terminable interest property (QTIP) election 和 a portability election. 

The 188bet亚洲真人体育下载 called on the IRS in its 2016年5月12日的信 (以及在其 2014 和 2015 letters) commenting on the agency’s priority plan to “provide guidance, such as a revenue procedure, under section 2010(c) regarding the validity of a QTIP election on an estate tax return filed only to elect portability.”  The 188bet亚洲真人体育下载 requested clarity regarding a 2001 牧师enue Procedure that treated QTIP elections void 和/or voidable if they were not needed to eliminate federal estate tax.  Estate planners have been needing this QTIP election guidance over the past few years as estates have been electing portability as they continued to face low state estate tax exemption amounts even though the federal exemption amounts have been higher since 2010.  在新的指导下, the IRS will not treat an unnecessary QTIP election as void if the executor has made a portability election.

The IRS promised this QTIP election guidance in the preamble to the January 2015 portability regulations, 和 on September 27 fulfilled that promise with the release of 牧师. Proc. 2016-49, providing the necessary guidance sought by the 188bet亚洲真人体育下载.  

For details about the guidance, read the 会计学杂志 故事.