Tax Brief Issue 14: 2027 PTC, CRAT Listing & Election Relief

01. 2027 PTC limits and CRAT listed transactions

• For taxable and plan years beginning in 2027, the Section 36B premium tax credit required contribution percentage is set at 10.22%.
• Effective July 9, 2026, certain charitable remainder annuity trust (CRAT) transactions that use purchased annuities to improperly bypass Section 664(b) tier rules are designated as listed transactions subject to mandatory disclosure and penalties.

Source: IRS Internal Revenue Bulletin · 2026-07-27

02. Late entity classification election relief granted

• The IRS continues to grant 120-day extensions under Section 301.9100-3 and Section 1362(b)(5) for entities to late-file Forms 8832 and 2553 to elect S corporation classification, provided the taxpayer acted in good faith and filed returns consistent with the requested relief.

Source: IRS Written Determinations · 2026-07-24

03. Relief for missed GST exemption allocations

• Taxpayers who missed a GST exemption allocation due to a tax professional's failure to advise can obtain an extension under Section 2642(g) to make the allocation retroactively at the property's original gift tax value.

Source: IRS Written Determinations · 2026-07-24