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Internal Revenue Bulletin:  2014-7 

February 10, 2014 


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Rev. Proc. 2014–18Rev. Proc. 2014–18

This revenue procedure provides an automatic extension pursuant to § 301.9100–3 for certain estates having no filing requirement under § 6018(a) to elect portability of the decedent’s unused exclusion amount for the benefit of the decedent’s surviving spouse pursuant to § 2010(c)(5)(A). The revenue procedure applies to estates of decedents dying after December 31, 2010, and before January 1, 2014, and includes estates of decedents survived by a same-sex spouse that were not eligible to elect portability until after the decision in United States v. Windsor, 570 U.S. ___, 133 S. Ct. 2675 (2013) and the publication of Rev. Rul. 2013–17, 2013–38 I.R.B. 201. Rev. Proc. 2014–3, 2014–1 I.R.B. 111, is Amplified.

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