Proposed regulations provide guidance for making the election under section 2632(c) of the Code to not have the deemed allocation of unused generation-skipping transfer (GST) tax exemption apply with regard to certain transfers to a GST trust. The regulations also provide guidance for making the election to treat a trust as a GST trust.

This procedure provides a simplified alternate method for certain taxpayers to obtain an extension of time under section 301.9100-3 of the regulations to make an allocation of the generation-skipping transfer exemption in accordance with section 2642(b)(1) of the Code. Notice 2001-50 modified.