The Tax Court agreed with the IRS that gift tax of approximately $10 million resulting from the gift of qualified terminable interest property (QTIP) by a decedent within three years before her death ...
Property passing from a decedent to the surviving spouse generally qualifies for the marital deduction under IRC section 2056. But a terminable interest, such as a life estate in a trust created by ...
There are five kinds of trusts that will qualify for the marital deduction: (1) the “qualified terminable interest property trust,” (2) the “life estate with power of appointment trust,” (3) the ...
The donee spouse has a “qualifying income interest for life” if (1) the donee spouse is entitled to all the income from the property, payable annually or at more ...
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The Internal Revenue Service has released new procedures that help a taxpayer make the decision on whether to opt for a qualified terminable interest property election to reduce estate taxes. The new ...