Rev. Proc. 2017-34
SECTION 1. PURPOSE
This revenue procedure provides a simplified method for certain taxpayers to
obtain an extension of time under § 301.9100-3 of the Procedure and Administration
Regulations to make a “portability” election under § 2010(c)(5)(A) of the Internal
Revenue Code (Code). For purposes of the Federal estate and gift taxes, a portability
election allows a decedent’s unused exclusion amount (deceased spousal unused
exclusion amount, or DSUE amount) to become available for application to the surviving
spouse’s subsequent transfers during life or at death. The simplified method provided
in this revenue procedure is to be used in lieu of the letter ruling process. No user fee is
required for submissions filed under this revenue procedure.
