In Revenue Procedure 2014-18, the Internal Revenue Service ("IRS") provided a simplified method of obtaining relief under § 301.9100-3 of the Procedure and Administration Regulations to make a Portability election under § 2010(c)(5)(A) of 
the Code.

For decedents who died after December 31, 2010 but before January 1, 2014 and were survived by a spouse, and for whom no Form 706 was required to be filed under § 6018(a) of the Code due to the decedent's gross estate and adjusted taxable gifts being under the applicable threshold at the time of the decedent's death, this Revenue Procedure permits an executor to file Form 706 to make a Portability election before December 31, 2014 with no filing fee. The Executor must file the Form 706 before December 31, 2014 and state at the top of the return: "FILED PURSUANT TO REV. PROC. 2014-18 TO ELECT PORTABILITY UNDER § 2010(c)(5)(A)."

If the taxpayer complies with these rules, the filed Form 706 is deemed timely filed for purposes of electing Portability for the decedent's surviving spouse. If, however, the IRS determines that a Form 706 should have been filed because the decedent had a gross estate plus adjusted taxable gifts in excess of the filing requirement, then the extension is null and void and the Form 706 may be considered untimely filed if not filed within the time period for filing.

If a taxpayer has a pending private letter ruling request for an extension of time to make a portability election and that decedent's estate would qualify under this Revenue Procedure, then the taxpayer may withdraw that ruling request and obtain a refund of the applicable user fee if the IRS is notified of such withdrawal before the earlier of March 10, 2014 and the IRS issuing a favorable ruling to the taxpayer.

If a taxpayer does not qualify for relief under this Revenue Procedure for any reason, the taxpayer may still file for Section 9100 relief under the general rules for requesting such an extension of time.