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Revocations and Rejections

Tuesday, April 21, 2015

Among this week's release of private letter rulings was one rejection letter, PLR 201516066.

Four PLRs Allow Late QSST Elections

Monday, April 20, 2015

In each of four unrelated rulings, PLRs 201516003, 201516009, 201516016, and 201516017, the Service granted inadvertent termination relief to an S corporation where the beneficiary of a decedent's trust did not make a timely QSST election.

PLR 201516055 - Late Filing of Final QDOT Notice

Monday, April 20, 2015

In PLR 201516055, the Service granted the trustee of a qualified domestic trust ("QDOT") an extension of time to file a notice that the surviving spouse had become a citizen.

Two PLRs Allow Late ESBT Election

Monday, April 20, 2015

In each of two nearly identical, related rulings, PLRs 201516001 and 201516002, the Service granted inadvertent termination relief to an S corporation where the trustee of an irrevocable inter vivos trust failed to make a timely ESBT election after the trust ceased to be a grantor trust.

PLR 201516019 - Settlement Does Not Affect GST Exempt Status

Monday, April 20, 2015

In PLR 201516019, the Service ruled the settlement of a controversy among beneficiaries of a pre-1985 trust would not affect its grandfathered GST tax-exempt status.

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