Revocation of QSST election. A QSST election may be revoked only with the consent of the Commissioner. The Commissioner will not grant a rev- ocation when one of its purposes is the avoidance of Federal income taxes or when the taxable year is closed. The application for consent to revoke the election must be submitted to the In- ternal Revenue Service in the form of a letter ruling request under the appro- priate revenue procedure. The applica- tion must be signed by the current in- come beneficiary and must— (i) Contain the name, address, and taxpayer identification number of the current income beneficiary, the trust, and the corporation with respect to which the QSST election was made; (ii) Identify the election being re- voked as an election made under sec- tion 1361(d)(2); and (iii) Explain why the current income beneficiary seeks to revoke the QSST election and indicate that the bene- ficiary understands the consequences of the revocation.
Appears in 9 contracts
Samples: Supplemental Contract, Publishing Agreement, Supplemental Contract