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5) For indirect skips that may be subject to an estate tax inclusion period ( A donor therefore cannot allocate GST exemption to a grantor retained annuity trust or qualified personal residence trust--where the trust property is included in her gross estate if she dies before her retained interest in the trust terminates--until the estate tax inclusion period ends (when the grantor dies, a generation-skipping transfer occurs with respect to the property, or the grantor's retained interest in the trust expires). The final regulations on automatic allocation to an indirect skip subject to an estate tax inclusion period ( |
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