Follow-up confirming a standard Form 872-H and Form 56 suffice for a sub-trust, with no special-trustee signature

Plain-English summary

This short Chief Counsel email follows up on advice about extending the assessment limitations period for a retirement trust that has a sub-trust. It clarifies that the Form 872-H (consent to extend the period for a trust) and Form 56 (notice of fiduciary relationship) are filled out in the usual way, and that no separate signature from the special trustee, and no mention of the sub-trust, is needed. It is brief internal guidance to IRS personnel, not a ruling for any taxpayer.

Ruling snapshot

• Question: For a sub-trust, does the Form 872-H and Form 56 need a special-trustee signature or a reference to the sub-trust?
• Outcome: Advice given (no; complete the forms as usual)
• Key authorities: Forms 872-H and 56 (consent to extend the limitations period; fiduciary notice)

Full text (IRS public release)

ID: CCA_2021121513525250_2 [Third Party Communication:

UILC: 401.00-00
Date of Communication: Month DD, YYYY]

Number: 202202013
Release Date: 1/14/2022
From: ---------------------
Sent: Wednesday, December 15, 2021 1:52:52 PM
To: ----------------------
Cc: ------------------------------------------------
Bcc:
Subject: RE: Subtrust F.5500 info

Hi Sarah, yes, to clarify, we are saying that the Form 872-H and 56 would be filled out
as typical, and no signature from the special trustee or mention of sub-trust is needed.

Jesse Hubbard
Attorney
CC:PA:02
202-317-4344