A gift tax deduction is allowed for outright transfers and interests in certain types of trusts given to a spouse who is a U.S. citizen. See § 2523. A similar deduction is allowed for estate tax purposes. § 2056. The estate tax marital deduction is also allowable for such transfers to a surviving spouse. If a decedent’s surviving spouse is not U.S. citizen, the deduction is allowable only if the transfers are made to a qualified domestic trust (QDT). § 2056A.
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