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401(a)(9)(B)(iii), an exception to the five-year rule applies to distributions made to (or for the benefit of) a designated beneficiary, if such distributions begin no later than one year after the death of the employee and are made over the life of the beneficiary (or over a period not extending beyond such beneficiary's life expectancy). The Court's required modification would change the specified date for Kaiser to file its Plan of Reorganization from no later than Dec. By filing a GST tax return that uses a purported inclusion ratio on Form 706GS(D), Generation-Skipping Transfer Tax Return for Distributions, and Form 706GS(D-1), Notification of Distribution From a Generation-Skipping Trust, the inclusion ratio would become final no later than the assessment period with respect to the transferor's estate. |
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