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.

TitleTitle 26: Internal Revenue PartPart 20: Estate Tax; Estates of Decedents Dying After August 16, 1954

SourceeCFR (current through Mar 20, 2026)

This text of 26 C.F.R. § 20.2056A-12 (Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.) is published on Counsel Stack Legal Research, covering United States primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook

26 C.F.R. § 20.2056A-12 (2026).

Text

§ 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]