2017-34 relief, the decedent's DSUE
is available to the surviving spouse or the surviving spouse's estate for application to the surviving spouse's transfers made on or after the decedent's death under Estate Tax Regs.
If portability is elected, the surviving spouse's applicable exclusion amount is his or her own basic exclusion amount plus the DSUE
If the election had been made, Jim's widow Marie's estate could have used Jim's DSUE
in addition to her own at her death.
When issuing final regulations (18) in June 2015 addressing requirements for electing portability of a DSUE
amount, Treasury and the IRS stated that later guidance would address whether a QTIP election made under Sec.
This would eliminate state estate tax upon the DS's death and permit the SS to utilize the DS's DSUE
The computation of the DSUE
amount is based on the basic exemption amount in effect in the year of the death of the decedent whose DSUE
amount is being computed.
This gift could use the DSUE
under IRC section 2519.
citizen may use the DSUE
amount if he or she subsequently becomes a U.
Another way to maximize the DSUE
amount would be to make a QTLP election for the irrevocable trust if it qualifies.
25 million DSUE
amount), a fee of $20,000 for an attorney to prepare the estate tax return is presumed reasonable.
On June 18, 2012, temporary(3) and proposed(4) regulations were issued to provide guidance on the portability of the deceased spousal unused exclusion (DSUE
) amount, including how to make the portability election and how a surviving spouse uses the DSUE
The last timely filed return including extensions will control the calculation of the DSUE