26 C.F.R. § 20.2056A-12 Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.
Title 26 - Internal Revenue
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]
Title 26: Internal Revenue
PART 20—ESTATE TAX; ESTATES OF DECEDENTS DYING AFTER AUGUST 16, 1954
Taxable Estate
§ 20.2056A-12 Increased basis for section 2056A estate tax paid with respect to distribution from a QDOT.
