More practically, however, the QDOT
can be terminated and all assets paid to the surviving spouse if he or she becomes a U.
Consequently, the executor will compute a DSUE amount on a preliminary basis on the decedent's estate tax return for purposes of electing portability, and this amount will subsequently be redetermined on the final distribution from the QDOT
or other taxable event on which the estate tax under Sec.
citizen or a domestic corporation, and the trust must provide that no distribution of principal be permitted unless such trustee may withhold from the distribution a special QDOT
Property passing to a QDOT
is eligible for the marital deduction.
To satisfy the QDOT
rules and obtain the marital deduction, not only does the property have to be transferred to a QDOT
and a timely election made on the estate tax return, but the marital deduction trust requirements must also be satisfied.
requirement was set in place by Congress under the Technical and Miscellaneous Revenue Act of 1988 and the Revenue Reconciliation Act of 1989 in reaction to the fear that noncitizen spouses would leave the U.
In addition to tax deferral, however, a QDOT
may also result in absolute savings.
The IRS ruled m the affirmative in Letter Ruling 9623063,(58) in which the surviving spouse, who was the primary beneificiary of the decedent's IRAs, timely rolled over the decedent's interest in the IRA to her own IRA, and irrevocably entered into a QDOT
agreement with respect to her IRA.
2056A(b)(1), a QDOT
secures the payment of the estate tax by taxing any distribution from the trust before the surviving spouses death and taxing the trust property remaining at that spouse's death.
The Qdots studied in this work are used to label receptors on the surface of lymphocytes and other biological cells.
Compared with organic dyes, Qdots exhibit sizetunable and spectrally narrow emission properties, efficient light absorption across a wide spectrum, outstanding photostability, and a large Stokes shift--attributes that can greatly expand the capability of fluorescence imaging.