Final regulations under section 2632(c)(5)(A)(i) of the Code provide guidance for making the election to not have the deemed allocation of unused generation-skipping transfer (GST) tax exemption under section 2632(c)(1) apply with regard to certain transfers to a GST trust, as defined in section 2632(c)(3)(B). The regulations also provide guidance for making the election under section 2632(c)(5)(A)(ii) to treat a trust as a GST trust.