" ... addresses tax planning for gratuitous transfers of property to a spouse who is not a U.S. citizen. Since 1988, the estate and gift tax marital deductions have been disallowed by [sections] 2056(d) and 2523(i) for transfers of property to a spouse who is not a U.S. citizen. Such transfers, whether made by gift or bequest, are fully subject to U.S. transfer taxes."
Formerly published in Washington, D.C., 2000-2007. Title from title screen (viewed Sept. 28, 2011).
Bibliography, etc. Note
Includes bibliographical references.
Formatted Contents Note
Detailed analysis. Introduction Disallowance of federal estate tax marital deduction Qualification as a QDOT When is qualification as a QDOT determined? Provisions for reformation Transfers by the surviving spouse of outright bequests and nonprobate property to a QDOT Special rules for nonassignable annuities and other arrangements Taxation of QDOTs Death of the noncitizen surviving spouse Federal gift tax on transfers to noncitizen spouses Effect of changes in the federal gift and estate tax marital deduction on U.S. tax treaties Effective date provisions Planning for the marital deduction for noncitizen spouses Working papers.
Digital File Characteristics
System Details Note
Mode of access: World Wide Web.