BarbriSFCourseDetails
  • videocam Live Webinar with Live Q&A
  • calendar_month March 4, 2026 @ 1:00 p.m. ET./10:00 a.m. PT
  • signal_cellular_alt Intermediate
  • card_travel Tax Preparer
  • schedule 110 minutes

Correcting GST Exemption Allocations: Remedies Available for Late and Improper Allocations

Early Bird Pricing!
MSRP
$347.00
$294.95
Save $52.05

Discount expires 1/28/26

This course is $0 with these passes:

CPE
ALL
  1. keyboard_arrow_leftBack
BarbriPdBannerMessage

About the Course

Introduction

This webinar will walk trust and estate professionals through the process of addressing missed and improper GST (generation-skipping transfer) exemption allocations. Our panel of estate planning experts will cover common scenarios that may create GSTT (generation-skipping transfer tax) obligations and provide illustrative examples of correcting unallocated and misallocated GST exemption amounts.

Description

GSTT is a 40% tax on transfers made to skip persons. IRC Section 2613 defines a skip person as a person two or more generations below the transferor's generation, or a trust, if all interests are held by skip persons or by trusts that will make no distributions to a nonskip person. Sheltering trusts and beneficiaries from this significant additional tax is a major component of wealth transfer plans. 

Prior to 2001, practitioners were required to allocate the GST exemption on timely filed gift tax returns. At the urging of trust and estate planners and the AICPA, the IRS implemented rules, effective for transfers after Dec. 31, 2000, that automatically allocate the GST exemption to certain transfers and provided guidelines for late allocations. In some situations, failing to opt out of these automatic allocations can prove costly.  

There are steps taxpayers, trusts, and their advisers can take to mitigate incorrect or unmade GST elections. Among these is the new automatic extension included in final regulations released in 2024. Trust and estate professionals need to understand the options available to correct inadvertent allocations of the GST exemption.

Listen as our panel of seasoned wealth planning advisers reviews actions estates can take to apply or reallocate the GST exemption.

Presented By

Jamie L. Carter
Partner
Haynes & Boone LLP

Ms. Carter is a partner in the Private Client and Estate Planning Practice Group. Her areas of practice include wealth preservation and estate planning, estate and trust administration and taxation, and charitable organizations. Ms. Carter's practice focuses on planning and drafting estate planning documents and assisting clients in planning for both large and small estates, including wills, trusts, prenuptial and postnuptial agreements, family limited partnerships, charitable organizations, and various other estate planning techniques; family wealth planning and preservation; administering trusts and estates of decedents; and assisting clients with the establishment of tax-exempt organizations, including public charities, private foundations, supporting organizations, charitable trusts, employer-sponsored scholarship and emergency/disaster relief funds, business leagues, social welfare organizations, performing arts and cultural groups, churches and religious organizations, amateur athletic organizations, and international aid organizations.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Jospeh Collins
Counsel
Haynes & Boone LLP

Mr. Collins is a counsel in the Estate Planning Practice Group in the Dallas office of Haynes Boone. His practice focuses on designing and implementing comprehensive estate plans and business succession techniques, while minimizing estate, gift, generation-skipping and income tax consequences; forming and administering family business entities; representing clients in probate matters; developing and implementing plans for protecting clients’ privacy; and advising clients on trust and estate administration matters.

expand_circle_down Expand to View Full Bio expand_circle_up Collapse Bio
Credit Information

  • BARBRI is a NASBA CPE sponsor and this 110-minute webinar is accredited for 2.0 CPE credits.

  • BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

Date + Time

  • event

    Wednesday, March 4, 2026

  • schedule

    1:00 p.m. ET./10:00 a.m. PT

I. Late GSTT elections: introduction

II. Background

A. History of GSTT

B. Revenue Procedure 2004-46  

C. Automatic allocations

III. Types of incorrect allocations

A. Unprotected transfers made before 2001

B. Unintended automatic allocations

C. Opting in or out of GST allocations

D. Other scenarios

IV. Remedies

A. Final regulations

B. Late allocations or amended returns

C. Section 2632(d) relief

D. Section 9100-Private Letter Ruling requests

V. Best practices

The panel will cover these and other critical issues:

  • Correcting opt-in and opt-out elections under the 2024 final regulations
  • Identifying trusts with skip persons
  • When a PLR is the best course of action to revise GST allocations
  • Filing late and amended returns to modify GST elections and allocations

Learning Objectives

After completing this course, you will be able to:

  • Identify taxpayers and trusts that would benefit from making a late GST allocation
  • Determine the importance of reviewing GST allocations on gift returns prior to 2001
  • Decide which individuals and trusts are considered skip persons
  • Ascertain how and when it may be necessary to request a PLR for misallocated GST exemptions
  • Field of Study: Taxes
  • Level of Knowledge: Intermediate
  • Advance Preparation: None
  • Teaching Method: Seminar/Lecture
  • Delivery Method: Group-Internet (via computer)
  • Attendance Monitoring Method: Attendance is monitored electronically via a participant's PIN and through a series of attendance verification prompts displayed throughout the program
  • Prerequisite:

    Three years+ business or public firm experience preparing complex tax forms and schedules, supervising other preparers or accountants. Specific knowledge and understanding of estate, gift and trust taxation including various trusts types, the unified credit, and portability.


BARBRI, Inc. is registered with the National Association of State Boards of Accountancy (NASBA) as a sponsor of continuing professional education on the National Registry of CPE Sponsors. State boards of Accountancy have final authority on the acceptance of individual courses for CPE Credits. Complaints regarding registered sponsons may be submitted to NASBA through its website: www.nasbaregistry.org.

IRS Approved Provider

BARBRI is an IRS-approved continuing education provider offering certified courses for Enrolled Agents (EA) and Tax Return Preparers (RTRP).

BARBRI CE webinars-powered by Barbri-are backed by our 100% unconditional money-back guarantee: If you are not satisfied with any of our products, simply let us know and get a full refund. Contact us at 1-800-926-7926 .