26 CFR § 20.2056A-12

26 CFR · Internal Revenue

§ 20.2056A-12 — Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.

eCFR · current through Aug 3, 2026

§ 20.2056A-12 Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.
Under section 2056A(b)(13), in the case of any distribution from a QDOT on which an estate tax is imposed under section 2056A(b)(1)(A), the distribution is treated as a transfer by gift for purposes of section 1015, and any estate tax paid under section 2056A(b)(1)(A) is treated as a gift tax. See § 1.1015-5(c)(4) and (5) of this chapter for rules for determining the amount by which the basis of the distributed property is increased.

[T.D. 8612, 60 FR 43551, Aug. 22, 1995]

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§ 20.2056A-12 Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.

Under section 2056A(b)(13), in the case of any distribution from a QDOT on which an estate tax is imposed under section 2056A(b)(1)(A), the distribution is treated as a transfer by gift for purposes of section 1015, and any estate tax paid under section 2056A(b)(1)(A) is treated as a gift tax. See § 1.1015-5(c)(4) and (5) of this chapter for rules for determining the amount by which the basis of the distributed property is increased.

[T.D. 8612, 60 FR 43551, Aug. 22, 1995]

26 C.F.R. § 20.2056A-12 (Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.