Qualified Domestic Trust (QDOT) Regulations – IRC §2056A

Current understanding

IRC §2056A governs qualified domestic trusts (QDOTs), which allow a U.S. citizen decedent’s estate to claim the marital deduction for property passing to a noncitizen surviving spouse by ensuring deferred estate tax is ultimately collected. Treasury/IRS finalized regulations modernizing outdated references and procedural mechanics of the QDOT regime without altering substantive policy — noncitizen-spouse beneficiaries and their estates remain subject to the same underlying tax treatment, with clearer administrative procedures.

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