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Beyond the GST of It

A review of the deemed allocation rules of Chapter 13 and their application to lifetime indirect skips.

Unlike Chapters 11 (estate tax) and 12 (gift tax) of the Internal Revenue Code, which in most cases apply either on death or during lifetime, respectively, because of the reconciliation process for lifetime gifts and includible assets at death that occurs on a decedent’s estate tax return, Chapter 13’s generation-skipping transfer (GST) tax spans both realms, sometimes lying in wait for, well, generations, before it reveals itself. As our calendars march towards Dec. 31, 2025, when absent

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